As part of its revisions to HMDA the Consumer Financial Protection Bureau (CFPB) is considering whether there is an opportunity to level the playing field between bank and nonbank lenders. Today, banks that meet certain conditions must submit annual reports even if they make only a single loan. However, nonbank mortgage lenders generally are required to report only if they make 100 loans and meet other conditions. The CFPB is considering a rule intended to […]
Tag: HMDA
WHERE’S HMDA HEADED – PART I – OVERVIEW
The Home Mortgage Disclosure Act (HMDA) was enacted by Congress more than 35 years ago to increase public scrutiny of access to credit and residential mortgage lending. HMDA data: Contains information about the vast majority of mortgage loans in this country; Shows whether lenders are serving the housing needs of their communities; Gives public officials information that helps them make decisions and policies; and Reveals lending patterns that could be discriminatory. The Consumer Financial Protection […]
COLLECTING GOVERNMENT MONITORING INFORMATION
The Fourth Quarter 2013 issue of Consumer Compliance Outlook, published by the Board of Governors of the Federal Reserve Board, contains an excellent article which reviews and compares the rules for collecting Government Monitoring Information (GMI) under Regulations B (Equal Credit Opportunity Act) and Regulation C (Home Mortgage Disclosure Act). The article is available here.
FLURRY OF YEAR-END THRESHOLD ADJUSTMENTS
The Consumer Financial Protection Bureau (CFPB) just completed the usual year-end chore of updating various thresholds. The changes are based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) for various periods in 2013. Escrow Exemption for HPMLs – On December 30, 2013 the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in […]
HMDA – HOEPA STATUS
Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under current rules a loan secured by a consumer’s principal dwelling is subject to HOEPA if the loan has a high rate or high fees. Currently a loan has high fees if the total points and […]