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Financial Services Law Insights and Observations

CFPB Issues Request for Information Regarding HMDA Disclosure Guidelines



On January 7, the CFPB announced that it will request public feedback on the resubmission of mortgage lending data reported under HMDA. Upon publication in the Federal Register, the Request for Information Regarding Home Mortgage Disclosure Act Resubmission Guidelines (Request for Information) will be open for 60 days. The Bureau’s Request for Information follows the agency’s October release of a final rule amending Regulation C to expand the reporting requirements of the HMDA regulation. Among other things, the amended rule increases the number of data points collected from financial institutions that must be reported to federal regulators beginning March 1, 2019, thus potentially necessitating revisions to the resubmission guidelines, which are the guidelines that describe when supervised institutions will be expected to correct and resubmit data. In response to questions regarding whether the CFPB will adjust mortgage lending data resubmission guidelines to reflect the new data requirements under the amended rule, the Request for Information seeks public comment regarding (among other things): (i) the CFPB’s use of resubmission error thresholds and how they should be calculated; (ii) whether error thresholds should vary depending upon an institution’s LAR entry size; and (iii) whether systemic and non-systemic errors should be treated differently, and, if so, how they should be distinguished from one another.

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