HMDA

Aligning Fair Lending Testing with Why Consumers Withdraw their Mortgage Applications

Download This Article Withdrawn applications reflect an increasing proportion of non-approved first-lien mortgage applications as denials have become relatively less numerous. A decade ago, based on 2009 HMDA data, denials comprised just over one-half (53 percent) of non-approved first-lien applications. Denials fell to less than one-third (31 percent) of non-approvals a decade later. Over the [...]

February 18th, 2021|

Updated Census Bureau Data May Create New Compliance Risk for Lenders in 2022

Download This Article With the transition between presidential administrations, new regulations, and the ongoing effects from the pandemic and corresponding economic crisis, lenders are facing a dynamic environment in 2021 with respect to managing compliance risk under Fair Lending laws and the Community Reinvestment Act (CRA). There is another factor, however, receiving less attention but [...]

January 25th, 2021|

Lessons From the Recent Washington Federal Bank HMDA Settlement

Download This Article The recent settlement between Washington Federal Bank and the Consumer Finance Protection Bureau of reporting violations under the Home Mortgage Disclosure Act (HMDA) demonstrates that mortgage lenders should maintain a high level of focus on their compliance management system. In this article, we compare the bank’s earliest and most recent 2017 HMDA submissions to uncover the likely sources of [...]

January 12th, 2021|

CFPB Fines Washington Federal $200,000 for HMDA Errors

Washington Federal Bank, N.A., already under a 2013 consent order addressing violations of Home Mortgage Disclosure Act (HMDA) reporting requirements, must pay a $200,000 civil money penalty and beef up its compliance management related to later violations under a consent order announced October 27th by the Consumer Financial Protection Bureau (CFPB). In the new consent [...]

November 10th, 2020|

CFPB Releases Updated Report on New and Revised HMDA Data Points for 2019

On August 27, 2020, the Consumer Financial Protection Bureau (CFPB) released its second report on the publicly released data submitted under the Home Mortgage Disclosure Act (HMDA) for 2019 mortgage lending activity. The new report provides an updated review of new and revised HMDA data points that were mandated for HMDA reporting in the CFPB’s [...]

August 28th, 2020|

CFPB Issues Interpretive Rule on Method for Determining Underserved Areas

On June 23rd, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule to provide guidance to creditors and other persons involved in the mortgage origination process about the way in which the Bureau determines which counties qualify as “underserved” for a given calendar year. issued Tuesday.  The guidance is necessary, the CFPB said, because [...]

June 25th, 2020|

Compliance in the Era of COVID-19: Managing Risk While Meeting Consumer Needs

Lending institutions play a unique and vital role in helping consumers and businesses recover from heavy economic hardships during the COVID-19 pandemic. Businesses are affected by the pandemic in differing ways:  for some it means a slight reprieve in activity and possible opportunity to implement system improvements. For lenders, however, it often necessitates rapidly processing [...]

June 1st, 2020|

ADI Announces Availability of Preliminary Snapshot of National 2019 HMDA Data

On April 1, 2020, the Consumer Financial Protection Bureau (CFPB) released the Modified Loan Application Registers (LARs) reflecting 2019 mortgage lending activity reported under the Home Mortgage Disclosure Act (HMDA). These reports represent the second release of HMDA data under the new rule implemented in 2015. Starting in 2018, under the 2015 HMDA Rule, financial [...]

April 13th, 2020|

2018 HMDA Data Now Available

On Friday, August 30, 2019, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data reported under the Home Mortgage Disclosure Act (HMDA) for 2018 lending activity. The newly released datasets follow the release of the modified HMDA data in March 2019, which provided lender-level datasets. The newly released data includes a static [...]

September 3rd, 2019|

CFPB Proposes Changes to HMDA Reporting Thresholds

Last week, the CFPB issued an Advance Notice of Proposed Rulemaking (ANPR) seeking information on the costs and benefits of reporting certain data points under HMDA and a Notice of Proposed Rulemaking (NPRM), wherein the proposal would raise the coverage thresholds for collecting and reporting data about closed-end mortgage loans and open-end lines of credit under [...]

May 6th, 2019|