As we get ready to finish up what has arguably been one of the most challenging years many of us have faced — both personally and professionally — I would like to kick off my first IMA President’s Message with a note of thanks. While we have been navigating unchartered waters regarding health and safety challenges, those in our industry have been blessed with an unexpectedly strong demand for housing coupled with near-historic low interest rates. This has resulted in record-breaking volume for many of us, as witnessed by the award winners announced at the IMA Fall Conference.

Speaking of the Fall Conference, I am thankful for the time we finally got to spend together (in person) during October. It has been two years since we were able to hold an in-person conference, and being able to share some quality time with our peers was long overdue. We tried some new things this year — some worked and some did not — but the support we received from IMA members, exhibitors and sponsors was great to see. Darcy Burnett did an amazing job pulling this together after what turned out to be years of uncertainty. A huge thank you to her!

Membership renewals will be sent via email to the IMA main contact in early December. Contact Darcy Burnett to receive a renewal invoice now.

The Consumer Financial Protection Bureau has announced several regulatory threshold changes in the Nov. 2, 2021 Federal Register that become effective Jan. 1, 2022. The thresholds are based on changes in the Consumer Price Index. Following is an overview of the regulatory adjustments that were announced.

The loan amount at which the Home Ownership and Equity Protection Act’s points-and-fees test comes into effect will increase to $22,969. The HOEPA points-and-fees trigger will rise to $1,148.

For qualified mortgages under the price-based general qualified mortgage loan definition in §1026.43(e)(2), the thresholds for the spread between the annual percentage rate and the average prime offer rate in 2022 will be:

For all categories of QMs, the thresholds for total points and fees in 2022 will be:

The Justice Department, Office of the Comptroller of the Currency and Consumer Financial Protection Bureau announced (DOJ Press Release 21-1039) a new initiative to combat redlining. Redlining is an illegal practice in which lenders avoid providing services to individuals living in communities of color because of the race or national origin of the people who live in those communities. In his prepared remarks, CFPB director Rohit Chopra, warned the CFPB “will also be closely watching for digital redlining, disguised through so-called neutral algorithms, that may reinforce the biases that have long existed.” Chopra also vowed the CFPB will “continue to contribute to the all-of-government mission to root out all forms of redlining, including algorithmic redlining.”

The new initiative represents the agencies’ most aggressive and coordinated enforcement effort to address redlining. The Initiative will expand the department’s analyses of potential redlining to both depository and non-depository institutions, strengthen the DOJ’s partnership with financial regulatory agencies to ensure the identification and referrals of fair lending violations to the Department of Justice, and increase coordination with state attorneys general on potential fair lending violations.

The deadline for mortgage loan originators to renew their registry with the NMLS (Nationwide Mortgage Licensing Registry) is Dec. 31, 2021. Those who fail to renew their NMLS registry are prohibited by federal law from acting in the capacity of an MLO after Jan. 1, 2022, until their registration is renewed. MLOs employed by federally regulated financial institutions must renew their annual registration. MLOs not employed by federally regulated financial institutions are also subject to state licensing requirements in addition to the NMLS registration requirement. Learn more.

The Consumer Financial Protection Bureau has released an update to the Filing Instructions Guide for data collected in 2022. The FIG is a technical resource to help financial institutions file Home Mortgage Disclosure Act data collected in 2022 and reported in 2023.

In addition, the Federal Financial Institutions Examination Council's Geocoder will use census tract information from the 2020 Census beginning Jan. 1, 2022. As a reminder, Regulation C, §1003.4(a)(9)(ii)(C) requires financial institutions to provide census tract information for certain properties. To determine what to report for this data point, a covered financial institution must look to the “most recent decennial census conducted by the U.S. Census Bureau” and “use the boundaries and codes in effect on Jan. 1 of the calendar year covered by the loan/application register that it is reporting.” As a result, for data collected beginning Jan. 1, 2022, financial institutions should use census tract information provided in the 2020 Census.