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From Banking and Finance Law Daily, October 13, 2017

CFPB updates small entity compliance guide for HMDA reporting

By Andrew A. Turner, J.D.

To support implementation of the recently issued amendments to Reg. C—Home Mortgage Disclosure (12 CFR Part 1003), the Consumer Financial Protection Bureau has updated the small entity compliance guide. The updates reflect changes and clarifications made on Aug. 24, 2017, to rulemaking in October 2015 that was intended to reduce the number of lenders that must file reports while requiring more data to be collected and reported.

Amendments. Updates to the small entity compliance guide reflect rule changes regarding:

  • institutional coverage and the uniform loan-volume threshold for open-end lines of credit;
  • transactional coverage for open-end lines of credit;
  • collection and reporting of applicant information;
  • effective date of enforcement provisions for larger volume reporters;
  • whether certain installment sales contracts are extensions of credit for purposes of the HMDA Rule;
  • an exclusion from coverage for certain preliminary transactions that consolidate new funds into a New York CEMA;
  • what constitutes a loan secured by a multifamily dwelling under the HMDA Rule;
  • the exclusion from coverage for temporary financing;
  • including certain distributions from retirement and other asset accounts when reporting income;
  • reporting the universal loan identifier and use of check digit tool provided by the Bureau;
  • reporting loan purpose;
  • reporting property address and location when certain information is unknown or unavailable;
  • reporting census tract using the geocoding tool provided by the Bureau;
  • reporting combined loan-to-value when the calculation includes property other than the identified property;
  • reporting credit score when there are multiple scores or multiple applicants;
  • securitizers and automated underwriting systems;
  • reporting interest rate, rate spread, and certain other datapoints when revised or corrected disclosures are provided;
  • reporting the introductory rate;
  • reporting rate spread, including for applications that are approved but not accepted;
  • reporting mortgage loan originator identifier for certain purchased covered loans; and
  • reporting action taken if there is a counteroffer.

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