CFPB issued final policy guidance describing modifications that CFPB intends to apply to the loan-level data that financial institutions report under the Home Mortgage Disclosure Act (HMDA) and Regulation C, before the data is disclosed to the public. This final policy guidance applies to HMDA data compiled by financial institutions in or after 2018 and made available to the public by CFPB beginning in 2019.
Earlier, CFPB had issued consultation on this policy guidance and it received 26 comments on the proposed policy guidance. These included general comments on CFPB's proposal, views on the proposed treatment of particular data fields, and comments on other topics. The majority of the comments received did not address how CFPB should treat specific data fields and many comments opposing or expressing concerns with the proposal did not provide any evidence or analysis in support of their positions.
CFPB intends to commence a rulemaking in the spring of 2019, which will enable it to more definitively identify modifications to the data that CFPB determines to be appropriate under the balancing test and to incorporate these modifications into a legislative rule. The rulemaking will reconsider the determinations reflected in this final policy guidance, based on the experience of CFPB in administering the final policy guidance in 2019 and on a new rulemaking record, including data on the privacy risks posed by the disclosure of the HMDA data and the benefits of such disclosure in light of the purposes of HMDA. The final policy guidance on disclosure of loan-level HMDA data is a non-binding general statement of policy and/or a rule
Related Link: Federal Register Notice
Keywords: Americas, US, Banking, HMDA, Loan Level HMDA Data, Regulation C, Mortgage Disclousers, Dodd Frank Act, CFPB
Douglas W. Dwyer leads Corporate Credit Research in Predictive Analytics. This group produces credit risk metrics of small businesses, medium sized enterprises, large corporations, financial institutions, and sovereigns worldwide. The group’s models are used by banks, asset managers, insurance companies, accounting firms and corporations to measure name specific credit risk for a wide variety of purposes. We measure credit risk using information drawn from financial statements, regulatory filings, security prices, derivative contracts, behavioral and payment information. For each asset class, the methodology is developed based on the available information for each obligor. <br><br> Current projects include developing a climate adjusted probability of default and incorporating ESG factors into credit analytics. We also are developing an approach to produces comparable PDs across asset classes that opportunistically uses whatever information is available. <br><br> Prior to working at Moody’s Analytics, Dr. Dwyer was a Principal at William M. Mercer, Inc., in their Human Capital Strategy practice. Dr. Dwyer earned a Ph.D. in Economics at Columbia University and a B.A. in Economics from Oberlin College.
Financial economist; recognized expert on credit risk and default research, credit ratings, modeling, analytics and stress-testing; specializes in Asia-Pacific economic, regulatory, and credit risk trends/analysis
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