Written by Steve Van Beek
2013 HMDA Guide. Yesterday, the Federal Financial Institution Examination Council (FFIEC) issued the 2013 HMDA Getting it Right! guide. According to the main page:
"The 2013 edition reflects the transfer of authority over Regulation C from the Federal Reserve Board to the Consumer Financial Protection Bureau. Appendix D, comment 1003.2 (Financial Institution)-2 is updated with the asset-size threshold exemption applicable to collection of 2013 data. There are also minor changes to the general text of the Guide, including updates to Sources of Geographic Information and Submitting the LAR."
You can find the full PDF of the 2013 Guide here.
Long Time Coming. Now, you may be wondering when the last version of the Guide was issued? 2010. The 2011 version would have been the lame duck one when the Federal Reserve still had authority for Regulation C (HMDA). However, there was no guide issued. On July 21, 2011, the CFPB took over Regulation C and they failed to release a guide in 2012. Fortunately, in year two, the CFPB found the time to update the Guide and provide guidance to HMDA-reporting institutions.
Garbage In, Garbage Out? The CFPB is a self-described "data-driven" agency. If you doubt it, take a read through this Bloomberg.com story: U.S. Amasses Data on 10 Million Consumers as Banks Object. To me, if you want to be data-driven - the best first step is to make sure your regulatory requirements are clear and understandable so that the data you collect (whether it be consumer complaints, HMDA data, or anything else) is as reliable as possible. But, that's just me.
NAFCU Calendar. NAFCU has a new calendar on our website that features:
- Compliance Deadlines;
- Important Regulatory Dates;
- Education & Conferences;
- CU Research Survey Deadlines; and
- Other Important Dates.
The calendar allows you to navigate month-by-month, click to find more information and add dates to your own calendar. For example, the "more information" link on the June 1st Escrow Changes Deadline includes this information:
CFPB Compliance Deadline: Escrow RequirementDescription:
Amended escrow requirements for higher-priced mortgage loans. Added a new small creditor exemption for credit unions that meet a four-part test.
Regulatory Text: 12 CFR 1026.35
NAFCU Compliance Blog: Mortgage Reform - Escrows
NAFCU Resources: www.nafcu.org/mortgagerules/#escrow
Download the latest full Compliance Calendar, including proposed regulations, past deadlines and more.
Date:Jun 01, 2013
NAFCU Members. The Mortgage Rules webpage includes NAFCU's Regulatory Alert on the CFPB's recent proposed rule. The proposal was published in the Federal Register yesterday and only provided 15-days for comments (comments to NAFCU on the Regulatory Alert are due on Wednesday, April 24).