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MoFo Reenforcement The Enforcement Blog

HMDA, HMDA, HMDA

Posted in CFPB, Enforcement Actions, Regulatory Developments

The Bureau has released updated Home Mortgage Disclosure Act data, updating its massive database to include 17 million records from 2013. Anyone can now go to the website and slice and dice more than 130 million records to “compare data across state, loan type, and more.” For its part, the Bureau observed that home purchase volume continued to increase in 2013, while refinancings declined in part due to rising interest rates. Of course, all this data will soon be dwarfed by the additional information the Bureau would collect pursuant to its proposed amended HMDA rules. As we detailed in our article and alert, the Bureau’s 573-page proposed rule would make sweeping changes to Regulation C, which implements HMDA, raising privacy concerns and dramatically expanding financial institutions’ HMDA reporting and compliance obligations, as well as their fair lending work more broadly, particularly in light of the Bureau’s renewed emphasis on HMDA enforcement. Angela Kleine discusses these concerns in the latest issue of the Bank Safety & Soundness Advisor. Adding to the privacy concerns, the GAO recently released a report concluding that the Bureau “need[s]” to make “additional efforts . . . in several areas to reduce the risk of improper collection, use, or release of consumer financial data.” We are continuing to monitor these issues, as industry comments are due on October 22, 2014. And, as noted below, you can hear an in depth analysis of the proposed rule and its potential impacts on lenders, litigants, and borrowers at the upcoming HMDA Panel, featuring Thomas Noto, at MBA’s Regulatory Compliance Conference 2014.