On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) released the anticipated final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA).
HMDA and Regulation C have long required covered lenders to collect and report certain data about mortgage applications, which the federal government uses to assess a covered institution’s fair lending risk. The new rule, which is intended to implement amendments made to HMDA by the Dodd-Frank Act, makes several important changes to Regulation C. These changes include:
- dramatically broadening the data that covered institutions must collect (around 25 new data points are added and around a dozen existing data points are modified);
- effectively expanding the scope of covered non-depository institutions and slightly narrowing the scope of covered depository institutions through implementation of loan-volume thresholds for triggering application of Regulation C; and
- modifying the scope of covered products.