The CFPB issued a proposed rule on May 2, 2019 that would change the HMDA reporting requirements and could have a significant impact on smaller financial institutions. The proposed rule would increase the closed-end coverage threshold from 25 to 100 loans originated in the previous two years. Additionally, it proposes to extend the current open-end threshold of 500 lines of credit until January 1, 2022. The proposed rule would also incorporate new interpretations and procedures into Regulation C. If this were to become part of the HMDA regulation, it would not take effect until January 1, 2020.
On May 1, 2019 the Consumer Financial Protection Bureau posted a factsheet regarding whether Loan Estimates (LE) and Closing Disclosures (CD) were required for assumption transactions. The factsheet consists of a flowchart and a narrative discussion to assist lenders in making the determination whether a loan would require the TILA-RESPA Integrated Disclosures. The factsheet can be found at https://files.consumerfinance.gov/f/documents/cfpb_tila-respa-factsheet.pdf.
Regulatory Solutions specializes in TRID loan reviews, please contact us to schedule your review today.
As CEO of this company, I sleep a little better at night, knowing that you are auditing our files and watching our backs. Thanks.