Archive

HAS REDLINING ENFORCEMENT RETURNED?

At the end of the Obama administration redlining consent decrees were becoming coming. Redlining cases, once the purview of large banks, had drifted down to the community bank level. Since the beginning of 2016 redlining cases have dried up, other than one case left over from the prior administration that was settled favorably for the bank. On June 13, 2009 The Department of Justice (DOJ) and the U.S. Attorney’s Office for the Southern District of […]

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URLA – THE MOST RECENT OFFICIAL APPROVAL

On November 20, 2017 the Consumer Financial Protection Bureau (CFPB) published its most recent Official Approval of the redesigned Uniform Residential Loan Application (URLA) to include an applicant language preference question. The first Official Approval of the URLA, which was issued by the CFPB on September 23, 2016: • Clarified that the relevant language in the redesigned URLA is in compliance with the regulatory provisions of Regulation B § 1002.5(b) through (d), regarding requests for […]

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URLA IMPLEMENTATION TIMELINE

On September 26, 2017 Fannie Mae and Freddie Mac (the GSEs) published guidance on the implementation timeline for the redesigned Uniform Residential Loan Application (URLA). Demographic Information Addendum The Consumer Financial Protection Bureau (CFPB) has finalized their Technical Corrections and Clarifying Amendments to the Home Mortgage Disclosure Act (HMDA) Regulation C. The GSEs have updated the Demographic Information Addendum based on this final rule. The changes were made only to the form instructions and not […]

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REGULATION B FINAL RULE – MONITORING INFORMATION

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. Regulation B includes restrictions regarding lenders’ ability to ask consumers about their race, color, religion, national origin or sex, except in certain circumstances. These circumstances include required collection of the information for some mortgage applications […]

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PROPOSED CHANGES TO REGULATIONS B AND C

The CFPB has been busy with proposed changes in recent weeks.  Two proposed changes released by the CFPB will impact most financial institutions to some degree.  The CFPB released proposed changes to Regulation B on March 24, 2017.  The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected.  In addition, the CFPB released changes […]

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