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Warren W. Traiger quoted in American Banker article, “Relief from HMDA requirements may go further than banks realize”

American Banker

Warren W. Traiger

Warren W. Traiger was quoted on August 2, 2018 in an American Banker article, “Relief from HMDA requirements may go further than banks realize,” which discussed the Home Mortgage Disclosure Act reform and the recent clarification from a FDIC official regarding data collection for small lenders. The article stated, “One point of confusion: Do reforms enacted in May reducing Home Mortgage Disclosure Act reporting fields for small lenders mean they still have to collect the data? An official at a recent Federal Deposit Insurance Corp. meeting suggested that banks qualifying for the exemption are under no obligation to collect the data internally, except in certain rare circumstances. ‘From our point of view, we do not think the law requires you to collect the data if you don't have to report it,’ said Jonathan Miller, deputy director for the FDIC’s division of depositor and consumer protection, at the meeting of the agency's community bank advisory panel. ‘It’s completely up to you whether you want to do it for whatever internal purposes, fair lending or for other purposes.’ Miller's comments have been seen by some as a significant sign of where regulators may be going. Although the Consumer Financial Protection Bureau writes all the rules and guidance related to HMDA, prudential regulators like the FDIC are tasked with monitoring their banks below a $10 billion asset threshold for compliance.”

Traiger noted, “It’s significant in the sense that it hasn’t been said before but it’s also highly logical. It would not surprise me if the [CFPB] guidance adopts what Jonathan Miller said.”

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