In the October 29, 2019, issue of the Federal Register (84 FR 57946) the Bureau of Consumer Financial Protection (CFPB) issued a final rule amending Regulation C (12 CFR Part 1003), which implements the Home Mortgage Disclosure Act (HMDA), to adjust the institutional...
Client & Friends Memo
Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.
CFPB Proposed Rule to Amend HMDA Regulation C
In the May 13, 2019, Federal Register (84 FR 20972, click here) the Consumer Financial Protection Bureau (CFPB) published a proposed rule to amend Regulation C to: (i) propose two alternatives to increase the threshold for reporting data about closed-end mortgage...
HMDA Asset-Size Exemption Threshold Increased for 2019 – Regulation C, Supplement I, Paragraph 1003.2-2(g)
In the January 31, 2019, issue of the Federal Register (Vol. 84, No. 513, click here) the Bureau of Consumer Financial Protection published a final rule amending the official staff commentary in Supplement I to Regulation C (12 CFR part 1003), which implements the...
CFPB Releases Beta Version of 2018 HMDA Data Platform
As a companion to the HMDA Examiner Transaction Testing Guidelines memorandum posted on our website yesterday, www.bmandg.com/resources/, this memorandum advises you that the CFPB has released a beta version of the 2018 HMDA data platform. The beta release...
HMDA Examiner Transaction Testing Guidelines
As the 2018 HMDA data reporting deadline of March 1, 2019, is approaching, this memorandum is to remind our clients who report HMDA date of the Federal Financial Institutions Examination Council’s HMDA Examiner Transaction Testing Guidelines published last year on...
CFPB Issues HMDA Interpretive Rule
In the September 7, 2018, issue of the Federal Register (83 FR 45325, click here), the Consumer Financial Protection Bureau issued an interpretive and procedural rule (the “Interpretive Rule”) to implement and clarify the requirements of section 104(a) of the Economic...
Asset-size Thresholds Revised for HMDA and TILA in 2018
In the December 27, 2017 issue of the Federal Register, the following annually revised asset-size thresholds were published to be effective January 1, 2018: Home Mortgage Disclosure Act/Regulation C (82 FR 61145, click here) The CFPB has added comment -2 under the...
CFPB Issues Public Statement Regarding 2018 HMDA Data
On December 21, 2017, the CFPB issued a Public Statement for HMDA data collected in 2018 and reported in 2019 (click here). In the Public Statement, the CFPB states that it does not intend to require data resubmission unless data errors are material or assess...
CFPB Launches Beta Test Version of HMDA Platform
Today the CFPB announced the beta launch of the new HMDA Platform. For your information and use, the text of the CFPB announcement is reprinted below: The main objective of the release is to provide financial institutions an opportunity to become familiar with the...
Regulation C (HMDA) Amendments
In the September 13, 2017, issue of the Federal Register (82 FR 43088, click here) the CFPB published a final rule amending its 2015 HMDA (Regulation C) Final Rule to: (i) make technical corrections and clarify certain requirements; (ii) temporarily increase the...