2017 Regulation B Final Rule – Monitoring Information

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On September 20, 2017 the Consumer Financial Protection Bureau (CFPB) published final revisions to Regulation B, which implements the Equal Credit Opportunity Act (ECOA), to provide additional flexibility for mortgage lenders in the collection of consumer ethnicity and race information. The rule is generally effective on January 1, 2018.

The revised rule allows non-HMDA creditors to collect the applicant’s information using either the aggregate ethnicity and race categories (as the information appears on the old Uniform Residential Mortgage Application (URLA) form) or disaggregated ethnicity and race categories and subcategories (as the information appears on the revised URLA). HMDA creditors are required to collect using disaggregated ethnicity and race categories and subcategories.

The rule also makes certain changes to the Regulation B Appendix B – Model Forms. The rule provides two options: a model form for collecting aggregate applicant race and ethnicity information and a cross-reference to the Regulation C appendix model form for collecting disaggregated applicant race and ethnicity information. The rule also removes as outdated the existing version of the URLA contained in the Regulation B appendix, effective January 1, 2022.

Upon completion participants will understand the revised rules regarding collection of monitoring information under Regulation B.

Description

On September 20, 2017 the Consumer Financial Protection Bureau (CFPB) published final revisions to Regulation B, which implements the Equal Credit Opportunity Act (ECOA), to provide additional flexibility for mortgage lenders in the collection of consumer ethnicity and race information. The rule is generally effective on January 1, 2018.

The revised rule allows non-HMDA creditors to collect the applicant’s information using either the aggregate ethnicity and race categories (as the information appears on the old Uniform Residential Mortgage Application (URLA) form) or disaggregated ethnicity and race categories and subcategories (as the information appears on the revised URLA). HMDA creditors are required to collect using disaggregated ethnicity and race categories and subcategories.

The rule also makes certain changes to the Regulation B Appendix B – Model Forms. The rule provides two options: a model form for collecting aggregate applicant race and ethnicity information and a cross-reference to the Regulation C appendix model form for collecting disaggregated applicant race and ethnicity information. The rule also removes as outdated the existing version of the URLA contained in the Regulation B appendix, effective January 1, 2022.

Upon completion participants will understand the revised rules regarding collection of monitoring information under Regulation B.

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