Currently Regulation C requires creditors to report information regarding loans and applications made for one of three purposes: Home purchase; Home improvement; or Refinancing. Reporting of home equity lines of credit (HELOCs) used for these purposes is generally optional. Under Regulation C’s existing transaction reporting regime, certain loans that are secured by residential real property need not be reported (e.g., home equity loans with no stated purpose, HELOCs, certain reverse mortgages). Yet home improvement loans […]
Tag: Regulation C
WHERE’S HMDA HEADED – PART 2 – WHICH INSTITUTIONS ARE SUBJECT TO HMDA?
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 […]
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 […]
STATUS OF HMDA UPDATE
The Dodd-Frank Act has made substantial changes to the Home Mortgage Disclosure Act (HMDA). Now it appears that the regulation writing process is in high gear. Recently Richard Cordray, Director of the Consumer Financial Protection Bureau (CFPB), announced his agency is convening a Small Business Review Panel, as required by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA). The convening of a SBREFA panel is a preliminary step in the process of releasing […]
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.