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CFPB SPRING 2020 AGENDA

On June 30, 2020, the Consumer Financial Protection Bureau (CFPB) published its Spring 2020 Agenda. The agenda lists the regulatory matters that the CFPB expects to focus on between May 1, 2020 and April 30, 2021. Those matters include: A final rule amending the CFPB’s Remittance Rule to provide tailored exceptions that permit certain insured institutions to disclose estimates instead of exact amounts to consumers in certain circumstances. The final rule also increases (from 100 remittance […]

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CLARIFICATION OF REVISED HMDA CLOSED-END THRESHOLD

As of January 1, 2020 the threshold for reporting closed-end loans for purposes of HMDA was 25 loans. As announced last Friday, on July 1, 2020 the threshold increases to 100 closed-end loans. As a result, institutions that originate: Fewer than 25 closed-end loans continue to be exempt from reporting closed-end loans for HMDA; 25 or more, but fewer than 100, closed-end loans become exempt from reporting closed-end loans for HMDA effective July 1, 2020 […]

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NEW HMDA REPORTING THRESHOLD

On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about: Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of […]

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CFPB EXPANDS HMDA FAQS

On March 6, 2020 the Consumer Financial Protection Bureau added a new question and answer to its Home Mortgage Disclosure Act FAQs. The new Question 7. appears under the heading Ethnicity, Race, and Sex and § 1003.4(a)(10)(i) Question:  If a natural person applicant submits a mail, internet, or telephone application under Regulation C but does not provide race, ethnicity, or sex information, what should the financial institution report regarding whether this information was collected on […]

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2020 HMDA GUIDE

On February 12, 2020 the Federal Financial Institutions Examination Council (FFIEC) published its 2020 version of A Guide to HMDA Reporting – Getting It Right. The Guide, which has been published since 1998, provides a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data. The 2020 version is updated to include information from the final rule published by the CFPB in October 2019. Primarily, the 2020 Guide […]

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