CFPB PROPOSES AMENDMENTS TO REGULATION B

On March 24, 2017, the CFPB announced a proposal to amend various sections of Regulation B regarding collection of an applicant’s ethnicity and race information. These proposed amendments are intended to align with HMDA’s demographic information collection requirements that take effect January 1, 2018.

Today’s HMDA rules require banks to collect and report an applicant’s information using the ethnicity and race categories set forth in §1002.13(a)(1)(i) of Regulation B. The new HMDA rules; however, will allow applicants to self-identify using ethnicity and race subcategories, which will no longer correspond with Regulation B. The effective date for the proposal would the same day the new HMDA rules take effect (January 1, 2018).

In a nutshell, the proposal would:

  • Allow lenders to collect applicant information when they would not otherwise be required to do so. This is, of course, as long as they collect the information in compliance with HMDA.

This will benefit those banks that may not be subject to HMDA one year and then subject to HMDA the next or vice versa. They will be able to maintain consistent compliance procedures from year-to-year.

  • Allow lenders additional flexibility to collect an applicant’s information using either today’s ethnicity and race categories or the new HMDA ethnic and racial subcategories.
  • Remove and add optional Model forms from Appendix B to Regulation B.
  • Amend Regulation B to also include requirements to retain any additional information obtained pursuant to the proposal.

Comments on the proposal are due 30 days after it is published in the Federal Register.

For more information on this proposal, we plan to address it in more detail in our May Newsletter as well as our upcoming HMDA webinars. We’ve got you covered!

Published
2017/03/30
Deb Irving
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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