The CFPB extended the deadline for public comments on its advance notice of proposed rulemaking (ANPR) relating to the Bureau’s 2015 Rule addressing the Home Mortgage Disclosure Act (HMDA). The ANPR, issued on May 2, requested comments by July 8, 2019, on whether the CFPB should revise the data points lenders must report under the… Read More
The CFPB announced on Wednesday, September 20th, 2017, proposed guidance to limit the Home Mortgage Disclosure Act (HMDA) data it shares publicly. The Bureau’s 2015 HMDA amendments (discussed in our alerts here and here) revamped HMDA’s coverage and processes, including requiring lenders to report vast swaths of new data about mortgage applicants and their loans…. Read More
As we have previously reported, in October 2015, the CFPB issued a sweeping final rule (“2015 Final Rule”) to amend Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The bulk of the 2015 Final Rule will become effective on January 1, 2018. With the effective date drawing nearer, the CFPB has proposed an… Read More
Given the outcome of the presidential election, the focus is now on President-Elect Trump’s campaign promises to scale back the Dodd-Frank Act and pursue deregulation of financial services. As of now, little is known about specific actions the new administration will pursue after inauguration. There is, however, a template for reform, namely, the Financial Creating… Read More
On Thursday, February 25, 2016, the CFPB held a Consumer Advisory Board meeting in which it outlined its forward-looking supervision and enforcement priorities. After the Board meeting, the CFPB published a summary of these priorities that promises the following, among other things, during the next two years: Rulemakings related to arbitration and debt collection; Rigorous… Read More
On February 18, the CFPB and the Federal Financial Institutions Examination Council (FFIEC) published new “File Specifications” for data to be collected pursuant to the Home Mortgage Disclosure Act (HMDA) and its implementing regulation, Regulation C, in 2017 and 2018. These File Specifications follow the CFPB’s October 15, 2015, final rule (the “Rule”) amending Regulation… Read More
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: Covered institutions, i.e., the types of institutions required to… Read More
Just in time for the holidays, the CFPB released its Fall 2015 rulemaking agenda on Friday, November 20. The agenda does not include any major surprises, but it does slightly revise the projected timeline for several highly anticipated rulemaking activities. This alert lays out the highlights to consider between doses of turkey, football, and family…. Read More
December 3, 2015 1:00 pm – 2:30 pm EST Morrison & Foerster partners Nancy Thomas and Angela Kleine will speak on the “Consumer Protection Provisions in the Dodd-Frank Act: Adjusting to the New Paradigm” Lorman webinar on December 3. Click here to register.
On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to Regulation C in four broad areas: (1) the types of institutions required to collect and report HMDA data;… Read More
On Wednesday, July 29, 2015, the Fed is hosting a free webinar on “Common Violations and Hot Topics.” Senior staff will cover areas of common and/or substantive concern—including HMDA, ECOA (with a focus on spousal signatures), UDAAP, and the Flood Disaster Protection Act—and conduct a Q&A with participants. Registration is required.
In September 2014, Morrison & Foerster partner Angela Kleine spoke at the Mortgage Bankers Association’s Regulatory Compliance Conference. Attached is her presentation, “Litigation Forum: CFPB Enforcement.”
Morrison & Foerster partner Tom Noto will address the current regulatory landscape and fair lending & HMDA at the ComplianceEase User Advisory Council Meeting in Chicago. ComplianceEase User Advisory Council Meeting Saturday, May 2, 2015 – Sunday, May 3, 2015 Chicago, IL
Join Morrison & Foerster Partners Angela Kleine, Don Lampe, and Tom Noto, and Of Counsel Joe Rodriguez for the MBA’s 2015 Legal Issues and Regulatory Compliance Conference. Ms. Kleine is moderating the “Fair Lending and Other Significant Litigation” panel, Mr. Lampe is a speaker on the “Enforcement and Examination Update” panel, Mr. Noto is a speaker on the “Home Mortgage Disclosure Act on the Horizon”… Read More
This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement authorities, the CFPB is poised to issue a number of proposed rules and finalize several other rules it proposed… Read More
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… Read More