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«Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide Table of contents Table of contents 1. Introduction 1.1 Purpose of this guide ...»

-- [ Page 1 ] --

December 2015

OMB Control No. 3170-0008

Home Mortgage

Disclosure (Regulation C)

Small Entity Compliance Guide

Table of contents

Table of contents

1. Introduction

1.1 Purpose of this guide

1.2 Additional implementation resources

2. Key changes and effective dates

2.1 Institutional coverage

2.2 Transactional coverage

2.3 Required data points

2.4 Collection and reporting of applicant information

2.5 Annual reporting

2.6 Quarterly reporting

2.7 Disclosure requirements

2.8 Enforcement provisions for larger-volume reporters

3. Institutional coverage

3.1 Institutional coverage during 2017

3.2 Institutional coverage on or after January 1, 2018

3.3 Exempt institutions

4. Transactional coverage


4.1 Covered loans

4.2 Reportable activity

5. Reportable data

5.1 Applicant information

5.2 Universal loan identifier (ULI)

5.3 Application date

5.4 Application channel

5.5 Preapproval request

5.6 Loan type

5.7 Loan purpose

5.8 Loan amount

5.9 Loan term

5.10 Action taken and date

5.11 Reason for denial

5.12 Property address and location

5.13 Construction method

5.14 Occupancy type

5.15 Lien status

5.16 Manufactured home information

5.17 Property value

5.18 Total units

5.19 Multifamily affordable units

5.20 Debt-to-income ratio

5.21 Combined loan-to-value

5.22 Credit score information


5.23 Automated underwriting system information

5.24 Interest rate

5.25 Introductory rate period

5.26 Rate spread

5.27 Contractual features

5.28 Data points for certain loans subject to Regulation Z

5.29 Transaction indicators

5.30 Mortgage loan originator identifier

5.31 Type of purchaser

6. Recording and reporting

6.1 Recording

6.2 Reporting

6.3 Disclosure of data

7. Enforcement provisions

8. Mergers and acquisitions

8.1 Determining coverage

8.2 Reporting responsibility for calendar year of merger or acquisition..... 93

8.3 Changes to appropriate Federal agency or TIN

8.4 Determining quarterly reporting coverage

9. Practical implementation and compliance considerations

9.1 Identifying affected institutions, products, departments, and staff...... 97

9.2 Implementation and compliance management support activities...... 100 Attachment A:

Sample data collection form……………………………………………………………….…103


Attachment C:


According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and, notwithstanding any other provision of law, a person is not required to respond to a collection of information unless it displays a valid OMB control number. The OMB control number for this collection is 3170-0008. It expires on January 31, 2016. The information collections created by the Final Rule published October 28, 2015 at 80 FR 66127, have been submitted to OMB for approval, but have not yet been approved by OMB. These information collections will not become effective until either three years from the date of publication of this rule, or upon approval from OMB; whichever date is later. The time required to complete this information collection is estimated to average between 161 hours and 9,000 hours per response depending on the size of the institution. The obligation to respond to this collection of information is mandatory per the Home Mortgage Disclosure Act, 12 U.S.C. 2801-2810, as implemented by CFPB’s Regulation C, 12 CFR part 1003. Comments regarding this collection of information, including the estimated response time, suggestions for improving the usefulness of the information, or suggestions for reducing the burden to respond to this collection should be submitted to the Consumer Financial Protection Bureau (Attention: PRA Office), 1700 G Street NW, Washington, DC 20552, or by email to PRA@cfpb.gov. The other agencies collecting information under this regulation maintain OMB control numbers for their collections as follows: Office of the Comptroller of the Currency (1557–0159), the Federal Deposit Insurance Corporation (3064–0046), the Federal Reserve System (7100–0247), the Department of Housing and Urban Development (2502–0529), and the National Credit Union Administration (3133–0166).


1. Introduction The Home Mortgage Disclosure Act (HMDA), which Congress enacted in 1975, requires certain financial institutions 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. The datarelated requirements in HMDA and Regulation C serve three primary purposes: (1) to help determine whether financial institutions are serving their communities’ housing needs; (2) to assist public officials in distributing public investment to attract private investment; and (3) to assist in identifying potential discriminatory lending patterns and enforcing antidiscrimination statutes.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) transferred rulemaking authority for HMDA to the Consumer Financial Protection Bureau (Bureau), effective July 2011. It also amended HMDA to require financial institutions to report new data points and authorized the Bureau to require financial institutions to collect, record, and report additional information. On August 29, 2014, the Bureau published proposed amendments to Regulation C to implement the Dodd-Frank Act changes and to make additional changes. The Bureau carefully reviewed and considered the comments it received on its proposed amendments. On October 15, 2015, the Bureau issued a final rule (2015 HMDA Rule) amending Regulation C. The 2015 HMDA Rule was published in the Federal Register on October 28, 2015. The 2015 HMDA Rule implements the Dodd-Frank Act amendments and makes other changes to Regulation C.


1.1 Purpose of this guide The purpose of this guide is to provide an easy-to-use summary of Regulation C, as amended by the 2015 HMDA Rule, and to highlight information that financial institutions and those that work with them might find helpful when implementing the 2015 HMDA Rule.

This guide meets the requirements of Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, which requires the Bureau to issue a small entity compliance guide to help small entities comply with new regulations. Larger entities may also find this guide useful.

This guide is not a substitute for the 2015 HMDA Rule or Regulation C. Regulation C, the 2015 HMDA Rule, and their official interpretations (also known as the commentary) are the definitive sources of information regarding their requirements. The 2015 HMDA Rule is available at http://www.consumerfinance.gov/regulatory-implementation/hmda/.

The focus of this guide is Regulation C, as amended by the 2015 HMDA Rule. Except when specifically needed to explain a provision of amended Regulation C, this guide does not discuss other Federal or State laws that may apply to mortgage lending.

This guide has examples to illustrate some portions of the 2015 HMDA Rule. The examples do not include all possible factual situations that could illustrate a particular provision, trigger a particular obligation, or satisfy a particular requirement. Even though an example may identify a fictitious financial institution as, for example, “Ficus Bank” or “Ficus Mortgage Company,” the provision or obligation being illustrated in the example may apply to all financial institutions, including both depository and nondepository financial institutions.

Sometimes this guide will distinguish between the requirements of the 2015 HMDA Rule and the requirements of Regulation C as they apply before a specific part of the 2015 HMDA Rule goes into effect. When making these distinctions, the guide generally refers to the requirements of Regulation C as they apply before a specific part of the 2015 HMDA Rule goes into effect as “current Regulation C.” However, it should be understood that this means the requirements of Regulation C as they are before the specific part of the 2015 HMDA Rule being discussed goes into effect, not Regulation C as of any specific date (such as the date the guide is being read).


1.2 Additional implementation resources Additional resources to help institutions understand and comply with the 2015 HMDA Rule are available on the Bureau’s website at http://www.consumerfinance.gov/regulatoryimplementation/hmda/.

A person who has a specific regulatory interpretation question about the 2015 HMDA Rule after reviewing these materials may submit the question in writing to CFPB_RegInquiries@cfpb.gov.

Please specify HMDA in the subject line and provide regulatory cites to indicate the topic of the question. Any person without access to email may leave his or her question in a voicemail at 202-435-7700. Bureau staff provides only informal responses to regulatory inquiries, and the responses do not constitute official interpretations or legal advice.

Generally, Bureau staff is not able to respond to specific inquiries the same business day or within a particular requested timeframe. Actual response times will vary based on the number of questions Bureau staff is handling and the amount of research needed to respond to a specific question.

Technical questions about collecting or reporting 2015 and 2016 HMDA data (reported in 2016 and 2017) should continue to be directed to hmdahelp@frb.gov or 202-452-2016. Technical questions about collecting HMDA data for 2017 and later years or reporting HMDA data in 2018 and later years should be directed to hmdahelp@cfpb.gov or 855-438-2372.


2. Key changes and effective dates The 2015 HMDA Rule changes: (1) the types of financial institutions that are subject to Regulation C; (2) the types of transactions that are subject to Regulation C; (3) the data that financial institutions are required to collect, record, and report; and (4) the processes for reporting and disclosing HMDA data.

Most provisions of the 2015 HMDA Rule go into effect on January 1, 2018 and apply to data collected in 2018 and reported in 2019 or later years. However, an institutional coverage change for depository institutions is effective January 1, 2017. Certain changes regarding reporting and changes to the enforcement provisions regarding good faith efforts are effective January 1, 2019.

The new quarterly reporting requirement is effective January 1, 2020.

This section summarizes these key changes and provides the effective date for each key change.

For an illustration of the 2015 HMDA Rule’s effective dates, see the HMDA Key Dates Timeline.

For more detailed information on the 2015 HMDA Rule’s specific requirements, see Sections 3 through 8.

2.1 Institutional coverage Effective January 1, 2017 through December 31, 2017 for certain changes to depository institution coverage; effective January 1, 2018 for broader changes to institutional coverage The 2015 HMDA Rule changes institutional coverage in two phases.

First, the 2015 HMDA Rule narrows the scope of depository institutions subject to Regulation C in 2017. A bank, savings association, or credit union is not subject to Regulation C in 2017


unless it meets all of the coverage criteria for depository institutions under current Regulation C, and it originates at least 25 home purchase loans (including refinancings of home purchase loans) in both 2015 and 2016. 12 CFR 1003.2 (financial institution)(1).

Second, effective January 1, 2018, the 2015 HMDA Rule adopts a uniform loan-volume threshold for all financial institutions. Beginning in 2018, a financial institution will be subject to Regulation C if it originated at least 25 covered closed-end mortgage loans in each of the two preceding years or at least 100 covered open-end lines of credit in each of the two preceding calendar years, and it meets other applicable coverage requirements. For depository financial institution coverage, the 2015 HMDA Rule maintains current Regulation C’s asset-size threshold, location test, federally related test, and loan activity test. For nondepository financial institutions, the 2015 HMDA Rule retains the current location test. A nondepository financial institution is subject to Regulation C, effective January 1, 2018, if it originated at least 25 covered closed-end mortgage loans or at least 100 covered open-end lines of credit in each of the two preceding calendar and meets the location test. 12 CFR 1003.2(g)(1), (2).

For more information regarding which financial institutions are subject to the 2015 HMDA Rule, see Section 3 and the HMDA Institutional Coverage Charts.

2.2 Transactional coverage Effective January 1, 2018 for data collected on or after January 1, 2018 (to be reported in or after 2019) The 2015 HMDA Rule modifies the types of transactions that are subject to Regulation C and generally adopts a dwelling-secured standard for transactional coverage.

Beginning on January 1, 2018, Regulation C generally applies to consumer-purpose, closed-end loans and open-end lines of credit that are secured by a dwelling. 12 CFR 1003.2(d), (e), and (o).

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