OCC Proposes to Revise Home Mortgage Disclosures Under Regulation C

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. HMDA generates loan data that can be used to help determine whether financial institutions are serving the housing needs of their communities and to assist public officials in distributing public-sector investments to attract private investment to areas where it is needed. The data can also be used to assist in identifying possible discriminatory lending patterns and enforcing anti-discrimination statutes.

The Dodd-Frank Act transferred the authority to administer HMDA, including rule making authority, from FED to CFPB and transferred supervisory and enforcement authority for HMDA for depository institutions over USD 10 billion in consolidated assets from FED, FDIC, OCC, and NCUA to CFPB. Thus, on May 13, 2019, CFPB issued a proposed rule to amend Regulation C to adjust the coverage thresholds. The proposal sets out two alternatives to increasing the closed-end institutional and transitional coverage threshold—to either 50 or 100 closed-end mortgage loans in each of the preceding two calendar years. In addition, the temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage would extend to January 01, 2022. After the temporary extension expires, the open-end threshold would be 200 open-end lines of credit in each of the preceding two calendar years.

Related Link: Federal Register Notice

Comment Due Date: December 16, 2019

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