CFPB Proposes HMDA Clarifications

In case you missed it, the CFPB issued a proposal last week (which consists of about 150 bonus pages of HMDA goodness) to make some corrections and clarify changes to the HMDA final rule that will be shaking up the compliance world for the next couple of years.

The proposal includes:

  • CFPB plans for a geocoding tool that can be relied on for census tract information;
  • Clarifications for certain terms, such as temporary financing and automated underwriting system; and,
  • The establishment of some transition rules for two data points (loan purpose and the loan originator unique identifier) for certain purchased loans.

Under the proposal, loans to a person exclusively to construct a dwelling for sale would be considered temporary financing.  In other words, builder loans or spec loans would not be reportable under HMDA.  That’s good news!

Comments are due 30 days after the proposal is published in the Federal Register.  Stay tuned!

Published
2017/04/17
Kevin Edwards
Kevin Edwards

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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