The CFPB’s Final Rule Ups the Ante on Data Collection and Reporting Significantly
October 22, 2015
While lenders scramble to adapt to the Consumer Financial Protection Bureau’s integrated disclosure rule, the agency has released its long-awaited final rule under the Home Mortgage Disclosure Act, ratcheting up the industry’s data-reporting requirements – and the potential for more fair lending enforcement activity. Among the most significant changes within the 800-page regulation, the final rule modifies which institutions are subject to Regulation C and adopts a uniform loan volume threshold for depository and non-depository institutions. It excludes from institutional coverage firms that did not originate at least 25 closed-end mortgage loans in each of the two preceding calendar years or at least 100 open-end lines of credit in such a time period. The new rule also changes...