Mortgage Compliance

Last Ditch Effort to Delay HMDA

Better late than never, I guess. The Community Home Lenders Association sent a letter to acting CFPB Director Mulvaney seeking a delay in implementation of the new HMDA data collection and reporting requirements. That’s like betting on a long shot. They believe the new requirements are an unfair burden on small independent lenders. Further, they want a safe harbor from…

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do-what-you-say-you-mean-fixx-tila
Mortgage Compliance

Do What You Say and Say What You Mean

TILA requires a lender to provide an applicant with a good faith estimate of the fees that will be charged to, or imposed on, the applicant in connection with their loan. Seems simple, if you’re gonna charge it; disclose it. There’s a little catch, the fee must be for a service that is actually provided by the lender. For example:…

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mba-vs-cfpb-hmda-data
Mortgage Industry Trends

Role Reversal? MBA Worries About Consumer Protections

The MBA, along with other mortgage and banking industry trade groups, are challenging CFPB’s ‘Proposed Guidance’ for handling the disclosure of HMDA data. The CFPB proposes to exclude certain loan-level data points, modify other data points prior to disclosure, and disclose other information without modification. The trade groups say the disclosure of information will put the consumer at risk. Consumers…

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