Compliance Blog

Written by Michael Coleman, Regulatory Compliance Counsel

The Federal Reserve’s Consumer Compliance Outlook for the First Quarter 2012 contained a section on the most frequently asked questions from the Federal Reserve Board’s November 2, 2011, webinar entitled “Fair Lending Issues and Hot Topics.” Question #7 focused on how Dodd-Frank changed HMDA requirements and indicated that Section 1094 of Dodd-Frank amended HMDA to require financial institutions to collect and report new data for mortgage loans in the future.  The new data will include:

• Origination channel (retail, broker, or other)
• Applicant's age
• Applicant's credit score
• Property value
• Loan term
• Term (in months) of any introductory interest rate period
• Rate spread for all loans
• Total points and fees payable at origination
• Term (in months) of any prepayment penalty
• Negative amortization
• Loan originator unique identifier, universal loan identifier, and parcel loan number (as the CFPB may determine appropriate)

Dodd-Frank transferred authority over HMDA and Regulation C to the CFPB. The CFPB has not yet issued rules to implement the changes to HMDA and revise Regulation C, nor did it specifically mention the rule revising Regulation C in its "Semi-Annual Regulatory Agenda." However, the CFPB's Agency Rule List indicates that revisions to Regulation C are in the “prerule” stage.

Note: Dodd-Frank did not mandate a deadline for a final rule, but keep this issue on your radar, as we'll see amendments to HMDA at some point in the future.

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Free Member Call-In.  On Thursday, June 14 at 3:30 p.m. EDT, NAFCU will hold its mid-year Member Call-In.  The call is open to all NAFCU members but registration is required.  The call will feature NAFCU President and CEO Fred Becker and the association's government affairs team discussing latest developments in Washington affecting credit unions, including MBL, overdrafts, interchange, housing finance reform, CFPB, NCUA and more.  As always, you will have the ability to ask questions directly to NAFCU staff during the call.  

Don't miss out - register now for the June 14th NAFCU Member Call-In.  If you can't make the live call, the archived version is usually made available within a short period of time.