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MoFo Reenforcement The Enforcement Blog

Big Data, Big Government – Big Trouble? A Hard Look at the Final HMDA Rule

Posted in CFPB, Mortgage, Regulatory Developments

As previously reported, on October 15, 2015, the CFPB released a final rule (the “Rule”) amending Regulation C, 12 C.F.R part 1003, which implements HMDA. Shortly thereafter, we published a high-level summary of the Rule, describing the major changes to Regulation C across four broad areas:

  1. Covered institutions, i.e., the types of institutions required to collect and report HMDA data;
  2. Covered transactions, i.e., the types of transactions and applications subject to collection and reporting requirements;
  3. Loan-level data, i.e., the data about transactions that institutions must collect and report; and
  4. Reporting and disclosure, i.e., the method and frequency of reporting data and making that data available to the public.

This follow-up alert digs deeper into the Rule, while continuing to track its changes according to the four areas listed above. We give particular attention to some of the less-than-intuitive intricacies of the coverage tests for institutions and transactions, as well as to the new and modified loan-level data requirements.

Read our client alert.