May 20, 2019

OCC is soliciting comment on the revision of the information collection titled “Regulation C—Home Mortgage Disclosure.” OCC also notes that it has sent the collection to OMB for review. Comments must be submitted by June 19, 2019. Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requires certain depository and non-depository institutions that make certain mortgage loans to collect, report, and disclose data about originations and purchases of mortgage loans as well as loan applications that do not result in originations.

CFPB, on September 07, 2018, issued an interpretive and procedural rule to implement section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act. Section 104(a) amended certain provisions of the HMDA by adding partial exemptions from the HMDA requirements for certain insured depository institutions and insured credit unions. Insured depository institutions and insured credit unions covered by a partial exemption have the option of reporting exempt data fields as long as they report all data fields within any exempt data point for which they report data.

Section 104(a) of the EGRRCP Act amends HMDA section 304(i), which provides that the requirements of HMDA sections 304(b)(5) and (6) shall not apply with respect to closed-end mortgage loans of an insured depository institution or insured credit union if it originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. Sections 304(b)(5) and (6) of HMDA do not apply to open-end lines of credit of an insured depository institution or insured credit union if it originated fewer than 500 open-end lines of credit in each of the two preceding calendar years. The burden estimates have been adjusted based on section 104(a). OCC is soliciting comment in light of the section 104(a) changes. On February 14, 2019, OCC had published a notice for 60 days of comment regarding this collection. No comments were received. Comments continue to be invited on:

  • Whether the collections of information are necessary for the proper performance of the functions of OCC, including whether the information has practical utility
  • The accuracy of the estimates of the information collection burden
  • Ways to enhance the quality, utility, and clarity of the information to be collected
  • Ways to minimize the burden of the collection on respondents, including through the use of automated collection techniques or other forms of information technology
  • Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information

 

Related Link: Federal Register Notice

Comment Due Date: June 19, 2019

Keywords: Americas, US, Banking, HMDA, Regulation C, Mortgage Disclosures, EGRRCP Act, Dodd-Frank Act, Information Collection, CFPB, OCC

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