- CFPB Issues Final Rule Amending HMDA Reporting Requirements
- October 27, 2015 | Authors: Peter L. Cockrell; Brett M. Kitt; Gil Rudolph; J. Scott Sheehan
- Law Firms: Greenberg Traurig, LLP - McLean Office ; Greenberg Traurig, LLP - Washington Office ; Greenberg Traurig, LLP - Houston Office
- On Oct. 15, the CPFB issued a final rule amending the reporting requirements of the Home Mortgage Disclosure Act (HMDA). HMDA requires mortgage lenders to report certain information about the loans for which they receive applications or that they originate or purchase. Regulators and the public may use this information to assess lenders’ compliance with fair lending laws. The Dodd-Frank Act mandated specific new data points be collected and reported under HMDA. The CFPB used its discretionary rulemaking authority to expand the requirements further by adding additional data points not explicitly required by the Dodd-Frank Act.
The final rule adopts many of the provisions from the proposed rule, which was originally issued in 2014. The final rule requires lenders to report new information, including the property value, term of the loan, and the duration of any introductory interest rates. Lenders will also have to report loan pricing information, such as the borrower’s debt-to-income ratio, the interest rate of the loan, and the discount points charged for the loan. The rule also eases reporting requirements for certain small depository institutions.
Most of the provisions of the final rule take effect on Jan. 1, 2018. Mortgage lenders will therefore need to collect the new information in 2018 and then report that information by March 1, 2019.