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CFPB Proposes Significant Changes to HMDA Reporting Requirements

July 29, 2014
Joseph D. Simon
Garden City

The Consumer Financial Protection Bureau (“CFPB”) has issued proposed amendments to Regulation C, the regulation that implements the Home Mortgage Disclosure Act (“HMDA”). The proposed amendments would revise the tests for determining which institutions and loans are subject to Regulation C, significantly increase the information that must be reported on mortgage loans, require institutions which report a large number of loans to submit HMDA data quarterly instead of annually, allow institutions to make data available to the public through a website rather than at physical locations, and clarify certain unclear and confusing aspects of the regulation. Comments on the proposal must be received by the CFPB on or before October 22, 2014.

HMDA is a federal statute that requires financial institutions to collect and submit information on dwelling-secured loans to the federal government, and to make certain related information available to the public. The intent of HMDA is to provide the public with information about how lenders are serving the housing needs of their communities, and to promote access to fair credit in the housing market. The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) amended HMDA to try and improve the utility of HMDA data. This proposal by the CFBP implements the amendment made by the Dodd-Frank Act, but also contains significant other changes deemed advisable by the CFPB.

The following is a summary of the key elements of the proposal.

As noted above, comments on the on the proposal must be received by the CFPB on or before October 22, 2014. Comments may be submitted electronically to the CFPB by going to http://www.regulations.gov and following the instructions on that site. Comments should identify Docket No. CFPB-2014-0019 or RIN 3170-AA10. 

If you have any questions regarding these proposed amendments or HMDA in general, please feel free to contact Joseph D. Simon at (516) 357-3710 or via email at jsimon@cullenanddykman.com, Kevin Patterson at (516) 296-9196 or via email at kpatterson@cullenanddykman.com, or Elizabeth A. Murphy at (516) 296-9154 or via email at emurphy@cullenanddykman.com.