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Monday, August 25, 2014

ABA Issues Staff Analysis of Proposed HMDA Revisions

The CFPB’s Home Mortgage Disclosure Act changes would “significantly expand” the data that are collected — partly to meet congressional mandates but also to expand the bureau’s information on the mortgage market — according to an ABA staff analysis issued Friday.

As required by the Dodd-Frank Act, the proposal would require lenders to report an applicant or borrower’s age, loan rate, credit score, total points and fees, prepayment penalty, loan term, months to reset, non-amortizing payments, collateral value and application channel.

The CFPB also proposed requiring lenders to report a universal loan identifier, reason for denial, total origination charges, total discount points, the pre-discounted interest rate, the final interest rate, debt-to-income and loan-to-value ratios, information on manufactured housing, reverse mortgage status, Qualified Mortgage status and other data points. The bureau also proposed to revise the reporting of several pre-existing HMDA data points.

The analysis also provides detail on which lenders and what loans are subject to the proposal; covers several HMDA definitions that would change; and evaluates public disclosure terms, enforcement and the CFPB’s regulatory burden estimate.

Read the staff analysis.

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