TopMortgage Compliance Update (1)
July 21, 2010
HMDA: New Revisions Proposed


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Overview
On June 21, 2010, the Federal Reserve Board issued a notice of public hearings regarding potential revisions to Regulation C, Home Mortgage Disclosure Act (HMDA).

And on July 20, 2010, The Office of Thrift Supervision, Office of the Treasury, issued a transmittal of the Federal Register notice.

Hearings on the proposed revisions to HMDA will be held on July 15, 2010 in Atlanta, GA; August 5, 2010 in San Francisco, CA; September 16, 2010 in Chicago, IL; and September 24, 2010 in DC. Comments may also be e-mailed, faxed, or mailed.

Deadline for Comments: August 20, 2010

If you have any questions about this matter or would like assistance with mortgage compliance, please contact Jonathan Foxx, Managing Director or call 516-442-3456 x 100.
Highlights
Data Elements
  • What, if any, additional data should be collected? What are the benefits, costs, and privacy issues associated with requiring lenders to report, for example: (i) Underwriting data such as borrower's credit score, loan-to-value ratio, combined loan-to-value ratio (i.e., including both the reported loan and other debts), and borrower's debt-to-income ratio; (ii) borrower's age; (iii) loan originator channel; and (iv) rate spreads for all loans, instead of only for higher-priced loans?
  • Should any existing data elements be modified? If so, how? For example, what are the benefits, costs, and privacy issues associated with requiring lenders to report total income, rather than income relied on by the lender?
  • Should any existing data elements be eliminated? Why?
Coverage and Scope

Coverage
  • Should mortgage brokers and non-lender loan purchasers be required to report HMDA data?
  • Should other types of institutions be required to report? If so, which types?
  • Should any types of institutions be exempt from reporting?
  • Should the rules governing who must collect and report HMDA data be revised in other ways? If so, how?
Scope
  • Should any other types of mortgage loans be reported?
  • Should any types of mortgage loans be excluded from reporting?
  • Should the rules governing which mortgage loans are subject to reporting be revised in other ways? If so, how?
Preapproval Programs
  • Do lenders use preapproval programs as defined by Regulation C?
  • Is there a benefit to requiring lenders to report on these programs?
  • How could the definition of preapproval program be modified to be easier to apply and to make reporting more useful?
Compliance and Technical Issues
  • What are the most common compliance issues institutions face under HMDA and Regulation C?
  • What parts of Regulation C would benefit from clarification or additional guidance?
  • Are there technical issues regarding Regulation C that should be resolved?
Other Issues
  • Are there emerging issues in the mortgage market that may warrant additional research, respond to technological and other developments, reduce undue regulatory burden on industry, and delete obsolete provisions?
Visit Library for Issuance
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Office of Thrift Supervision, Department of the Treasury: Transmittal - TR-456, 7/20/10
Federal Register, Vol. 75, No. 118, pp. 35030-35033, 6/21/10

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