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

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If all goes according to plan, financial institutions will report over 250 million data points related to mortgage loan applications and originations in 2018. If the mortgage market returns to the high volumes seen in 2005, that number could top 750 million. This is an estimate of the data that the Consumer Financial Protection Bureau (CFPB) will require financial institutions to collect and report under the new Home Mortgage Disclosure Act (HMDA) Rule. That’s right, NSA. Be jealous.

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, on October 20, 2015, we published a high-level summary of the Rule, describing the major changes to Regulation C across four broad areas...

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