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; (2) the types of transactions and applications subject to collection and reporting requirements; (3) the data that must be collected and reported; and (4) the method and frequency of reporting data and making data available to the public.

This alert provides a high-level summary of the major changes to Regulation C in each of these four areas. We are continuing to examine the 796-page (and 560-footnote!) issuance, and we plan to provide a more detailed description and analysis following that review.