The CFPB has been busy with proposed changes in recent weeks. Two proposed changes released by the CFPB will impact most financial institutions to some degree. The CFPB released proposed changes to Regulation B on March 24, 2017. The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA. This proposal was not unexpected. In addition, the CFPB released changes […]
Tag: Regulation C
HMDA CLARIFICATION
On April 13, 2017 the Consumer Financial Protection Bureau published 150-page proposed update to Regulation C. The changes should help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. The proposal contains a number of clarifications, technical corrections, and minor changes to the HMDA regulation. These include clarifying certain key terms, such as “temporary financing” and “automated underwriting system.” The […]
HMDA – HUGE ERRORS, HUGE PENALTIES
Recently the Consumer Financial Protection Bureau (CFPB) ordered Nationstar Mortgage LLC, of Coppell, Texas, to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014, and to take the necessary steps to improve its compliance management and prevent future violations. This is the largest HMDA penalty ever imposed by the CFPB. According to 2014 data, Nationstar was […]
PHASE II OF THE HMDA REVISIONS
Implementing revised HMDA rules is a monumental task by any measure. The first phase is to determine scope and coverage, collect the data, and submit it to the CFPB. The second phase involves analyzing the data and determining the story told by that data. The scope of institutions covered by the revised rules has changed. The types of loans that are HMDA-reportable under the revised rules has changed. The list of information that must be […]
CFPB STANDS IN WAY OF SOLUTION TO HMDA REPORTING PROBLEM
Collection of 2017 HMDA data begins in less than two months. The Consumer Financial Protection Bureau announced last summer in its 2017 Filing Instructions Guide (FIG) that beginning with the HMDA data collected in 2017, filers will submit their HMDA data to the Consumer Financial Protection Bureau (CFPB) using a web interface referred to as the HMDA Platform. The HMDA Platform has not been released. That puts the industry in the awkward position of collecting 2017 […]