Banking Regulators Continue to Increase Reporting Requirements 

Banking regulators continue to implement increased reporting requirements pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and off the back of independent regulatory initiatives. In the most recent development, the Consumer Financial Protection Bureau (CFPB) updated the data collection and reporting required under the Home Mortgage Disclosure Act (HMDA).  In a statement, CFPB Director Richard Cordray said, “The Home Mortgage Disclosure Act helps financial regulators, the public, housing officials, and even the industry itself keep a watchful eye on emerging trends and problem areas in the nation’s mortgage market – the largest consumer financial market in the world. With today’s final rule we are shedding more light to foster better understanding of the market, and also ensuring that lenders have sufficient time to come into compliance.”

The final rule, published last Thursday, October 15, 2015, adds new data points to the existing dataset that mortgage lenders are required to submit to federal regulators annually. Some of the new data points were required by the Dodd-Frank Act, such as property value, loan term and teaser interest rates.  Other points were the result of Federal Reserve and CFPB examination.  The final rule will also increase the frequency of reporting for the largest financial institutions, originating more than 60,000 applications a year.  For those 30 or so lenders, HMDA reporting will be required quarterly in addition to a cumulative annual report.  The recent and rapid expansion of reporting requirements for the banking industry increase not only the regulatory burden for financial institutions, but also the liability for misreporting.


CFPB Press Release:

Final HMDA Rule:


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