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

Bloomberg BNA

Warren W. Traiger, Kari K. Hall

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. 

Special thanks is given to John Kimble, Associate at Buckley Sandler.