John Zasada, Compliance Consulting Director, Financial Institutions Group

On Nov. 16, 2021, the Consumer Financial Protection Bureau (CFPB) issued a 33-page Request for Information on the Home Mortgage Disclosure Act (HMDA). Over the last 45 years since its conception, HMDA has been updated and expanded over time. The CFPB is conducting a voluntary assessment of the HMDA final rule issued in 2015. In 2015, the CFPB expanded the types of loan data reported by lenders to help evaluate fair lending compliance.

An August 2021 HMDA report found mortgage lenders often deny credit and charge higher interest rates to Black and Hispanic applicants than they do to white applicants. In July 2021, an CFPB analysis of mortgage lending patterns within the Asian American Pacific Islander (AAPI) communities showed mortgage denial rates similar to those of Black and Hispanic borrowers.

To assess the effectiveness of the HMDA Rule, the CFPB intends to focus its evaluation on the following primary topic areas:

  • Institutional coverage and transactional coverage
  • Data points
  • Benefits of the new data and disclosure requirements
  • Operational and compliance costs

The CFPB views the assessment as an opportunity to evaluate whether prior HMDA rulemakings have improved upon the data collected, reduced unnecessary burden on financial institutions, and streamlined and modernized the way financial institutions collect and report HMDA data.

Gain insight on how HMDA reporting impacts your financial institution by contacting a Doeren Mayhew regulatory compliance specialist today.