CFPB: We’re working to make new HMDA implementation easier

Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.

The goal is to make the mind-numbing mortgage process much easier for consumers to understand. It’s called Know Before You Owe, which sounds simple enough. The means to that goal, however, is all-new.

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In October 2015, the CFPB adopted significant changes to the rules under the Home Mortgage Disclosure Act (HMDA). Among the changes, the items of information to be collected and reported under HMDA are greatly expanded, with some items being specified by Congress in the Dodd-Frank Act and others being added by the CFPB.

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The CFPB should work to implement a universal loan identifier to link all mortgage-related public databases, improve HMDA data by implementing the Dodd-Frank Act and our additional recommendations, and work with the Federal Financial Institutions Examination Council (FFIEC) to ensure that HMDA data are easily accessible to the public.

Working at CFPB  · You CAN start using the new 1003 today (according to the CFPB). If the loan is being sold, you’ll want to check with the investor. You have to start collecting the new Demographic Information on applications received 1/1/18, but that doesn’t have to be on the new 1003. It could be, but the CFPB has provided a different collection form.

 · HMDA Delay New Rule: Delay 2018 implementation of the new HMDA rule to better assess the privacy implications of the new requirements and examine the cost burden, particularly on small institutions Remove CFPB Authority: Consider moving the responsibility for administering HMDA back with the prudential regulators

the CFPB. According to the CFPB, HMDA data is important because it helps show whether lenders are serving the housing needs of their commu-nities, as they give public officials information that helps them make decisions and policies, and they shed light on lending patterns that could be discriminatory. The HMDA is the big “new”

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