The Home Mortgage Disclosure Act: Common Compliance Challenges

Since 2015, financial institutions have been inundated with reviewing and implementing numerous changes to the Home Mortgage Disclosure Act (“HMDA”) as required by the Dodd-Frank Act. The act transferred HMDA rulemaking authority to the Bureau of Consumer Financial Protection (“Bureau”), added new data points, and authorized the Bureau to require additional information from covered institutions. Specifically, in 2015, the Bureau issued the 2015 HMDA Final Rule implementing the Dodd-Frank Act amendments to HMDA through Regulation C. In 2017, the Bureau amended Regulation C to clarify certain requirements adopted by the Final Rule and to temporarily increase the loan threshold that is used to determine which financial institutions must collect and report loan data under HMDA.