April 23, 2019

April 23, 2019

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April 22, 2019

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Revised HMDA Examination Guidelines Issued

The CFPB recently posted on its website revised Home Mortgage Disclosure Act (HMDA) examination guidelines.

The revised guidelines address the exemption adopted in the Economic Growth, Regulatory Relief, and Consumer Protection Act (also known as S.2155) applicable to the new HMDA data categories added by Dodd-Frank and the HMDA rule adopted by the CFPB in October 2015. The exemption is available for insured depository institutions and insured credit unions that originate mortgage loans below certain thresholds and meet certain Community Reinvestment Act rating criteria. We previously reported on the exemption and a related interpretive rule issued by the CFPB in September 2018.

The Office of the Comptroller of the Currency also issued Bulletin 2019-19 that addresses the revised examination guidelines.

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About this Author

Richard J. Andreano, Jr. , Ballard Spahr Law Frim, Washington DC,  Business and Finance attorney, Mortgage Banking, Consumer Financial Services, Fair Lending

Richard J. Andreano, Jr., is the Practice Leader of Ballard Spahr's Mortgage Banking Group. He has devoted 30 years of practice to financial services, mortgage banking, and consumer finance law.

Mr. Andreano advises banks, lenders, brokers, home builders, title companies, real estate professionals, and other settlement providers on regulatory compliance and transactional matters, Federal Housing Administration (FHA) issues, and administrative examinations, enforcement actions and investigations. He also works with litigation counsel on devising strategies for defense of class action...

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