CFPB releases HMDA compliance guide

Regulation and Law

December 2, 2015

CFPB released a compliance guide for the Home Mortgage Disclosure Act rule on Tuesday, which includes detailed information on collection data points with examples of what is and is not reportable under the final rule.

The guide also explains the rule’s key changes and effective dates, institutional and transactional coverage and recording and reporting.

Under the rule, depository and non-depository institutions meeting all other criteria under Regulation C, and which originated 25 closed-end mortgage loans or at least 100 open-end lines of credit in each of the two preceding calendar years, will be required to report HMDA data when the provisions take effect. The first implementation deadline is in January 2017.

The rule makes significant changes to the types of loans that are subject to HMDA reporting under Regulation C. It expands the scope of reportable transactions to include most closed-end loans, open-end lines of credit and reverse mortgages secured by dwellings. Under this expansion, reporting will be required by credit unions that originate more than 100 home equity lines of credit a year.
 
In other provisions, the final rule requires reporting new data points about applicants and borrowers, property used to secure loans, loan features and unique identifiers.

NAFCU is running a series on the rule in its Compliance Monitor; the November issue featured the first article. NAFCU also issued a Final Regulation on the rule.

 

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