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Tag Archives: HMDA

CFPB Announces Public Comment Extension on HMDA Reconsideration

By Rick Fischer, Obrea Poindexter and Kathleen C. Ryan on Posted in CFPB, Mortgage, Regulatory Developments

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

CFPB Makes HMDA Data Sharing Proposal

By Angela Kleine on Posted in CFPB, Mortgage

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

Entering the HMDA Homestretch: CFPB Proposes Temporary Increase in HELOC Reporting Threshold, Releases New and Updated Filing Resources

By Don Lampe, Angela Kleine and Ryan Richardson on Posted in CFPB, Mortgage, Regulatory Developments

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

Whither the CFPB? In Uncertain Times, Rep. Hensarling’s Vision May See New Life

By Don Lampe and Amanda Mollo on Posted in Regulatory Developments

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

CFPB’s Two-Year Policy Priorities

By Ashley Hutto-Schultz on Posted in Arbitration, Auto Lending, CFPB, Mortgage, Student Lending

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

CFPB Publishes HMDA File Specifications for Data Collected in 2017 and 2018

By Leonard Chanin, Don Lampe and Ryan Richardson on Posted in CFPB, Mortgage

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

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

By Leonard Chanin, Angela Kleine and Ryan Richardson on 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: Covered institutions, i.e., the types of institutions required to… Read More

CFPB Publishes Semi-Annual Rulemaking Agenda

By Don Lampe and Ryan Richardson on Posted in Arbitration, Auto Lending, CFPB, Credit Reports, Mortgage, Payday Lending, Regulatory Developments, Student Lending

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

HOLY HMDA! CFPB Finalizes Changes to Home Mortgage Disclosure Rule

By Leonard Chanin, Angela Kleine and Ryan Richardson on Posted in CFPB, Mortgage, Regulatory Developments

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

Talk with the Fed About Compliance Hot Topics

By MoFoReEnforcement on Posted in Events, Mortgage, UDAAP

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.

MBA’s Legal Issues and Regulatory Compliance Conference

By MoFoReEnforcement on Posted in Enforcement Actions, Events, Fair Lending, Mortgage

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

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

By Don Lampe, Leonard Chanin and Joe Rodriguez on Posted in CFPB, Regulatory Developments, UDAAP

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

HMDA, HMDA, HMDA

By Angela Kleine and Tom Noto on 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… Read More