On July 24, the Consumer Financial Protection Bureau published long-awaited proposed revisions to its Home Mortgage Disclosure Act rules. The 573-page proposed rule would make sweeping changes to Regulation C, which implements HMDA, dramatically expanding financial institutions’ HMDA reporting and compliance obligations, as well as their fair lending work more broadly. The proposed changes include required reporting of 37 new data fields, 20 of which are not required by HMDA and represent additional information the CFPB would like to collect. In addition, the proposal would require “larger” HMDA reporters to report data every calendar quarter, rather than on an annual basis. We summarize here the key aspects of the proposal, how they compare to current HMDA requirements and what this all might mean for HMDA reporters in the future. Comments on the proposed rule are due by October 22, 2014.
HMDA was enacted in 1975 and has been expanded over the years from a statute aimed at basic monitoring and redlining prevention to one widely used by regulators and consumer advocates as a fair lending tool. It requires many depository institutions and other lenders to report information about the home loans that they decision, originate or purchase. For 2012, 7,400 financial institutions reported HMDA data relating to about 18.7 million loans. The Dodd-Frank Act required the CFPB to expand HMDA data reporting to include additional information about the applicants, lenders and loans.
Originally published in Law360 on August 12, 2014.
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