Just When You Thought It Was Safe to Take a Summer Vacation: CFPB Proposes Extensive New HMDA Rules

Last Thursday, the Consumer Financial Protection Bureau (CFPB) published its long-awaited new proposed revisions to its Home Mortgage Disclosure Act (HMDA) rules. The 573-page proposed rules 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 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) and required quarterly (rather than annual) reporting for larger institutions. We summarize here the key proposals, how they compare to current HMDA requirements, and what this all might mean for HMDA reporters in the future. (Hint: not many smiling faces.) Comments on the proposed rule are due by October 22, 2014.


HMDA was enacted in 1975, and has expanded over the years from a statute aimed at basic monitoring and redlining prevention, to one widely used by regulators and 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. According to the CFPB, as of 2012, about 7,400 financial institutions reported HMDA data relating to about 18.7 million loans. In 2010, the Dodd-Frank Act directed the CFPB to expand HMDA data reporting to include additional information about the applicants, lenders, and loans.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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