HMDA FIG

I have always enjoyed fruit. When I was a kid we always had a selection of fruits in the house, and on rare occasions we had a more exotic fruit, like figs. Most of my family didn’t like figs, so my Mom and I always split them. They were quite a treat. I haven’t had any figs in a while, but soon we all will have more FIG than we want.

Final revisions to Regulation C, which implements the Home Mortgage Disclosure Act, were published by the Consumer Financial Protection Bureau (CFPB) last October. The changes are massive. The new material consists of a revised Regulation C and the related Commentary. The new regulation does not include the old Appendix A, which were the instructions for completing the Loan Application Register (LAR). We also do not have a revised LAR or a revised HMDA Guide to Getting it Right.

The CFPB is developing a Filing Information Guide (FIG) to replace Appendix A. The CFPB has not yet announced a publication date. We suspect (and hope) that we will get the new LAR when we get the FIG. It is not yet clear if the CFPB will replace the HMDA Guide.

There is much that can be done now to begin the process of implementing the new HMDA rules, but the job cannot be completed without the FIG. We will let you know when it becomes available.

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