Compliance Blog

Written by Eliott C. Ponte, Law Clerk

2013 HMDA Data Available

On Monday, FFIEC announced the availability of the 2013 Home Mortgage Discourse Act (HMDA) data.  The HMDA data released includes information on lending activity, disclosure statements for each financial institution, aggregate data for each metropolitan statistical area, nationwide statistics, and lending patterns.  The raw data can be found on FFIEC’s HMDA website.

In commenting on the data, FFIEC made several observations, which include noting that the share of home purchase loans for 1-4 family properties made to black and Hispanic white borrowers declined from 2012, and that black and Hispanic white borrowers also experienced higher denial rates than non-Hispanic white applicants.  In contrast, the share of refinance loans to black and Hispanic white borrowers rose in 2013.

Also included in its observations was comments about the increase of higher-priced loans in 2013, which has increased from about 3% of loans in 2012 to about 5% of loans in 2013.  Higher-priced loans are defined as loans with APRs that exceed the average prime offer rates by at least 1.5 percentage points for first-lien loans and at least 3.5 percentage points for subordinate lien loans.  FFIEC stated that one reason for this increase is due to FHA increasing the annual mortgage insurance premium in April of 2013:

“One factor contributing to the overall increase in higher-priced lending was a sharp rise in the share of FHA-insured first-lien home purchase loans with APRs above the reporting threshold, from 4.6 percent in 2012 to 22 percent in    2013.  FHA raised its annual mortgage insurance premium (MIP) slightly in April 2013, and extended the period over which MIP is required to be paid by borrowers in June 2013.  All else equal, these changes, particularly the latter, would push up APRs for FHA loans.  About 75 percent of FHA purchase loans that met the higher-priced definition had APRs that were less than 0.5 percentage points above the higher-priced threshold.”

Additional observations about the 2013 data may be found in the FFIEC HMDA Data press release, or by reviewing the data listed on the HMDA website.

 

NCUA Removes Its Version of Regulations on Unfair or Deceptive Credit Practices

At the September 2014 NCUA Board meeting, the NCUA Board repealed NCUA’s regulations on unfair or deceptive credit practices.  The NCUA Board repealed its regulation in response to Dodd-Frank Act, which removed NCUA’s rulemaking authority under the Federal Trade Commission Act (FTC Act).  Credit unions are still required to comply with the FTC Act, which prohibits certain unfair and deceptive acts and practices.  While  NCUA no longer has rulemaking authority, it retains supervisory and enforcement authority.  Therefore, NCUA cautioned credit unions in the preamble for the repeal of Part 706 that the agency will still examine for compliance with the FTC Act.  NCUA continues to urge federal credit unions to review the Interagency Guidance Regarding Unfair or Deceptive Credit Practices (first issued to credit unions in 14-FCU-03).

 

NAFCU’s 2015 conference and online training lineup is here!

Start planning how you’ll get stronger in 2015 by adding trusted NAFCU training into next year’s annual budget.  Whether it’s online or in-person, the NAFCU training lineup is jam-packed with ideas and concepts to make both you and your credit union stronger.  We’ll help you cut compliance headaches, build revenue, streamline costs, and better strategize.  It’s beyond what you need; it’s what’ll help you exceed.

View NAFCU’s 2015 training lineup now.

 

Nuptial

This Saturday, I am getting married to my best friend and the love of my life.  I am so excited that this day has finally come.  On our first date, I thought I was the luckiest guy in the world because I had the pleasure of escorting a very intelligent and well-spoken women to dinner and a show.  Now, I know I am the luckiest guy in the world because she said yes!  These last five and ¾ years together have been a blast, and I am so excited to see what the next 50 plus years bring.

Because of my wedding, I will be out of the office for the next two weeks.  When I return, I promise to share some of my wedding/honeymoon pictures/stories with the blog.  Just for fun, I have included two pictures of me and my soon to be wife below.  Enjoy, and I will write you during/after NAFCU Seminar!

This is at my brother’s police academy graduation in 2010.  My hair is much shorter now.

 

This picture is from our law school graduation this past May.  We are still smiling.