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aRTiCLeS

          from examinations as examiners make multiple attempts at   application, the address of the property securing the loan and
          completing the program.                                the credit score or scores relied on in making the credit decision.
          To read the report visit: https://oig.federalreserve.gov/reports/  The bureau also proposed changes that would reduce the
          cfpb-examiner-commissioning-sep2017.pdf                precision of values reported for several data fields, such as the
                                                                 amount of the covered loan applied for, the age of an applicant
          CFPB Harmonizes Regs B                                 or borrower, or a borrower’s debt-to-income ratio.
          and C                                                  To read more visit: http://files.consumerfinance.gov/f/
                                                                 documents/201709_cfpb_hmda-disclosure-policy-guidance.pdf
          The CFPB has modified the Equal Credit Opportunity Act
          (Regulation B) to provide flexibility for lenders around the   CFPB Introduces Financial
          collection of applicants’ demographic data under the Home
          Mortgage  Disclosure  Act  (Regulation  C).  Reg  B  previously   Education Resource for People
          prohibited creditors from collecting information on consumers’   with Disabilities
          race or  ethnicity,  except  to  the  extent  required  to  monitor
          compliance with ECOA or comply with HMDA. The          The  CLPB  has  introduced a  companion guide,  Focus  on
          permissible inquiries under Reg B included only aggregate racial   People with Disabilities, to its Your Money, Your Goals toolkit
          and ethnic categories. However, under the new HMDA rules,   containing information, tips, and tools based on the insights
          banks must  permit applicants and borrowers to  self-identify   from people with disabilities and from organizations that serve
          using disaggregated ethnic and racial categories.      the disability community.
          The changes permit creditors to self-identify using disaggregated   To download the guide visit: https://s3.amazonaws.com/
          categories beginning on Jan. 1, 2017, enabling institutions to   files.consumerfinance.gov/f/documents/cfpb_ymyg_focus-on-
          use Fannie Mae and Freddie Mac’s new Uniform Residential   people-with-disabilities.pdf
          Loan Application prior to January 2018. The rule includes other   To view the toolkit visit: https://www.consumerfinance.gov/
          optional model forms to assure compliance with Regulation B   practitioner-resources/your-money-your-goals/
          requirements. It also allows institutions not subject to HMDA
          reporting requirements to choose on an “application-by-  ABA, ICBA Caution Against
          application basis” between two approaches to collecting personal
          demographic data: either the more limited, aggregate race and   Subjecting FDIC, Fed to
          ethnicity category required by Reg B, or the disaggregated   Appropriations Process
          and more expansive categories required for HMDA reporting
          institutions under Reg C effective in 2018.            The ABA and ICBA wrote to Senate Appropriations Committee
                                                                 leadership urging lawmakers to reject provisions included in the
          The rule does not add the 2016 URLA to the Regulation B   House appropriations bill for FY 2018 that would bring the
          appendix; according to the bureau that form is subject to a   FDIC and the non-monetary functions of the Federal Reserve
          separate Federal Register notice that will be issued by the CFPB    under the appropriations process. The groups noted that such
          in 2018.                                               a change would disrupt the current fee structure that banks
          To read more visit: http://files.consumerfinance.gov/f/  have already incorporated into their business plans, potentially
          documents/201709_cfpb_final-rule_regulation-b.pdf      requiring them to divert additional resources away from serving
                                                                 customers.
          CFPB Proposes Changes to                               “This radical change would also carry the very real possibility
          Publicly Reported HMDA Data                            of new fees and fee increases while bankers are bearing a sharp
                                                                 increase in regulatory compliance costs,” the letter stated. “The
          The CFPB has issued policy guidance on the loan-level Home   cumulative impact of these expenses will strain bankers’ ability
          Mortgage Disclosure Act data it will make available to the   to support economic growth and job creation.”
          public under the revised HMDA data collection rules, which
          take effect in 2018.                                   To read the letter visit: https://www.aba.com/Advocacy/
                                                                 LetterstoCongress/Documents/aba-icba-senate-supervision-
          Noting concerns over consumer identity protection, the CFPB   fees-091917.pdf
          is proposing to not publicly disclose a number of data points,
          including the universal loan identifier, the application date,
          the date of action taken by the bank on a covered loan or




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