It’s that time of year when HMDA LARs are being scrubbed, double-checked and submitted to regulators. Once you submit the data the agencies begin their quality checks, which often result in Macro and Micro Quality Edits that need your attention. Below are agency-provided answers to some of the most common questions about macro quality edits, reasons for providing detailed explana¬tions on the Macro Quality Edit Report, and examples of acceptable macro edit responses. What is […]
Tag: Lending Compliance
NEW CRA ASSET-SIZE THRESHOLDS
On December 19 the Federal Reserve Board published the new Community Reinvestment Act (CRA) asset-size threshold adjustments for small and intermediate small institutions. The adjustments are based on the change in the average of the Consumer Price Index (CPI) for urban wage earners and clerical workers, not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million. As a result of the 2.23 percent increase in the CPI index for […]
2013 THRESHOLDS
On November 20, 2013 the Consumer Financial Protection Bureau published notices increasing several thresholds for 2013. Two notices increased the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. The Dodd-Frank Act amendment the Truth in Lending Act and the Consumer Leasing Act to adjust these thresholds annually by the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical […]
EXTENDED DATE FOR NEW MORTGAGE DISCLOSURES
On November 16, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it will give creditors extra time to provide certain new disclosures required under the Dodd-Frank Wall Street Reform and Consumer Protection Act in order to allow a more seamless integration with other mortgage disclosures that have been proposed by the Bureau. The Dodd-Frank Act: Requires the CFPB to integrate certain disclosures from the Truth in Lending Act (TILA) and the Real Estate Settlement […]
HOW TO AVOID PROBLEMS RELATED TO UNEARNED DISCOUNT POINTS
This is the final part of a five part series that explores issues related to discount points. The previous articles provided a primer on discount points, explored UDAAP concerns that result from unearned discount points, considered how unearned discount points could lead to fair lending violations, and provided a glimpse of how Regulation Z revisions will change the handling of discount points in the future. In this part we discuss policies, procedures and controls needed […]