It's a New Dawn, New Day for HMDA Reporting

Bloomberg BNA
12 minute read | February.10.2016

On Oct. 15, 2015, the Consumer Financial Protection Bureau (the CFPB or the Bureau) issued its long-awaited final rule amending and drastically expanding the mortgage loan application data reporting requirements under Regulation C and the Home Mortgage Disclosure Act (HMDA). Lenders that are subject to the CFPB’s final rule — which weighs in at 797 pages — have their work cut out for them before it goes into effect on Jan. 1, 2018.

The purpose of this article is to help prepare lenders for the implementation of this rule, not only by explaining the types of institutions and transactions that are covered, the new data points that must be collected and reported, and the processes for reporting and disclosing this data, but also by suggesting the concrete steps that should be taken to ensure compliance with the final rule.

Originally published in Bloomberg BNA; reprinted with permission.

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Authors

Warren Traiger Senior Counsel, Financial & Fintech Advisory, Strategic Advisory & Government Enforcement (SAGE)

New York

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Financial & Fintech Advisory
Strategic Advisory & Government Enforcement (SAGE)
Fintech

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Warren Traiger Senior Counsel

New York

He argued before the U.S. Court of Appeals for the Second Circuit in Lee v. Board of Governors, a benchmark case regarding the rights of community organizations to challenge Federal Reserve Board (FRB) determinations on merger applications. He has testified before Congress and the federal banking agencies on fair lending and CRA reform, served as Special Counsel to the New York banking regulator on CRA, and advised the regulator on predatory lending regulation.

Warren regularly helps banks and bank holding companies prepare the community convenience and needs portion of their regulatory applications to merge or acquire, and he helps clients respond to public comment regarding CRA and fair lending compliance. He represented a bank in its acquisition and integration of the finance arm of major automaker, directing pre-acquisition fair lending due diligence and updating the combined entity’s policies, procedures and regulatory relations strategy. Warren also served as an independent consultant for the New York Attorney General, overseeing compliance with that office’s settlement with a company that provides criminal background checks on prospective employees.

A prolific writer and researcher, Warren’s research and statistical analysis of mortgage lending data has been cited in publications of the Federal Reserve Banks of San Francisco, Boston and Dallas; the Federal Deposit Insurance Corporation (FDIC); and in testimony before the U.S. House Financial Services Committee.

Prior to joining Orrick, Warren was senior counsel at Buckley LLP. He also served as Co-Chairman of Traiger & Hinckley LLP. Prior to entering private practice in 1990, Warren was vice president, counsel and director of government relations for the New York Bankers Association, the trade group for New York commercial banks. He also served as director of legislation and research and special counsel for the New York City Department of Consumer Affairs and as a New York State Consumer Protection Board official.

Warren is entrenched in the New York legal and financial services community. He has served on the Banking Law Committee of the New York State Bar Association, as a member of the Banking Law and Consumer Law Committees of the Association of the Bar of the City of New York, and has taught as adjunct professor of economics at Hunter College of the City University of New York.