CFPB Reaches Consent Orders for HMDA Violations


On October 9, 2013, the Consumer Financial Protection Bureau (“CFPB”) reached consent orders with two companies, Mortgage Master, Inc. (“Mortgage Master”) and Washington Federal, encompassing payment of civil penalties for violations of the Home Mortgage Disclosure Act (“HMDA”). The two orders resulted from examinations conducted by the CFPB that uncovered “violations of law and deficiencies” in the HMDA compliance systems of each entity. Under HMDA, mortgage lenders that meet certain threshold conditions must collect loan-level data in order to fulfill federal reporting requirements. HMDA reporting covers home purchase loans, home improvement loans, and refinancing transaction applications during each calendar year. HMDA does not provide for private rights of action. Financial institutions that are found to be in violation of HMDA, however, may be subject to administrative sanctions or civil money penalties. With the two consent orders, the CFPB demonstrated that it will initiate enforcement actions to ensure that institutions comply with HMDA’s requirements.


Mortgage Master is a nondepository mortgage lending institution headquartered in Massachusetts that originates and refinances home loans. Based on loan volumes, Mortgage Master was subject to HMDA and Regulation C. The CFPB’s examination and review that led to the consent order analyzed HMDA reporting data for 21,015 loans from 2011.

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