July Highlights
If you missed our July 2024 Monthly Connection, there was some great information provided on a variety of hot topics. These were addressed and then compliance questions submitted by the members were answered for the remainder of the hour.
Diane Dean offered key takeaways from the recent CFPB Fair Lending Report.
- HMDA was a recurring issue particularly with lenders failing to get demographic information. In one instance, a lender had such a severe problem that the required corrective action included recording telephone applications and auditing the results. Additionally, over a four-year period hundreds of loan officers failed to collect demographic information and instead falsely indicated the applicants chose not to provide it. The lender also paid a $12 million penalty.
- The CFPB has noted a decrease in this data being reported over the last few years and it is expected that more focus will be placed on this. HMDA reporters are expected to review their reporting and nonreporting rates of demographic information internally and address areas of concern.
Emily Riley offered information about 1071 data collection and the revised effective dates. She pointed out that financial institutions have more flexibility than there was in the original rule. Institutions may use origination volume from 2022-2023, or 2023-2024, and may select the period that provides it with the easier reporting tier.
In response to a member question Andy Zavoina discussed Reconsideration of Value (ROV) requirements. Andy pointed out that Freddie Mac, Fannie Mae and HUD has previously released guidance applicable to lenders selling mortgages to these entities. Freddie and Fannie’s rules take effect on August 29, 2024, and HUD’s effective date is September 2, 2024. Please note the July Monthly Connection occurred prior the final Interagency guidance issued on July 18, 2024, and those subject to the OCC, FRB, FDIC, NCUA and CFPB should review that guidance as well.
Finally, David Dickinson recapped the recent Supreme Court decision to overturn the “chevron doctrine” and what it means going forward.
Here are some excerpts from the Monthly Connection:
Published
2024/07/25
![Andy Zavoina](https://blog.bankerscompliance.com/hubfs/Screenshot%202024-07-25%20at%209.57.00%20AM.png)
Andy Zavoina
Andy Zavoina, CRCM, began his career in finance and banking in 1981 at a finance company. He landed in a proper bank in 1983 and spent 21 years in community banking. He managed loan workouts, has been a consumer, commercial and real estate lender, managed those departments, and was his bank's first webmaster. He was responsible for compliance management, auditing, and training. He then worked for BankersOnline for 21 years teaching webinars and conferences. Andy is a nationally recognized speaker at state associations and schools across the U.S. and has served on the faculty of national banking schools. He has had articles published and lectured on many facets of compliance, the use of the internet and technology as a compliance tool. Andy is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He chaired the ABA’s Compliance Executive Committee, its Editorial Advisory Board and served in other positions as well. Andy is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers.