As previously reported, on October 15, 2015, the CFPB released a final rule (the “Rule”) amending Regulation C, 12 C.F.R part 1003, which implements HMDA. Shortly thereafter, we published a high-level summary of the Rule, describing the major changes to Regulation C across four broad areas:
- Covered institutions, i.e., the types of institutions required to collect and report HMDA data;
- Covered transactions, i.e., the types of transactions and applications subject to collection and reporting requirements;
- Loan-level data, i.e., the data about transactions that institutions must collect and report; and
- Reporting and disclosure, i.e., the method and frequency of reporting data and making that data available to the public.
This follow-up alert digs deeper into the Rule, while continuing to track its changes according to the four areas listed above. We give particular attention to some of the less-than-intuitive intricacies of the coverage tests for institutions and transactions, as well as to the new and modified loan-level data requirements.
Read our client alert.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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