Fall into HMDA compliance: A chat with the Bureau

Hi Compliance Friends! Fall starts this Saturday, September 22nd. I hope that everyone is dusting off their favorite pumpkin recipes and preparing for the beauty of the fall foliage. As the world turns in compliance land, I’d like to brief you on the result of a recent regulatory inquiry I submitted to the CFPB, no the B-F-C, okay, the Bureau. I’ll just call them the Bureau.

For those not in the weeds on this topic, the Home Mortgage Disclosure Act (HMDA), which Congress enacted in 1975, requires credit unions to collect, record, report, and disclose information about their mortgage lending activity. Regulation C implements HMDA and sets out specific requirements for the collection, recording, reporting, and disclosure of mortgage lending information.

Generally, Regulation C applies to consumer-purpose, closed-end loans and open-end lines of credit that are secured by a dwelling. Regulation also C applies to business-purpose, closed-end loans and open-end lines of credit that are dwelling-secured and are home purchase loans, home improvement loans, or refinancing.

Pursuant to Regulation C, a credit union reports the interest rate applicable to covered loans or to applications that are approved but not accepted. For Applications that are denied, withdrawn or closed for incompleteness, Regulation C instructs a credit union to report this data point as not applicable or “NA”. But what about a loan offered at 0% interest, like a home equity line of credit with an introductory rate of 0%?


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