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.

1. 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.
2. 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