Home Mortgage Disclosure Act Reporting Requirements

CFPB is questioning whether to increase the data collected under the Home Mortgage Disclosure Act to better monitor trends and abuses in the market. This would possibly requiring lenders to explain why they rejected a loan and whether they thought it was a so-called “qualifying mortgage.” In addition, financial institutions would have disclose an applicant’s debt-to-income ration, the interest rate, the total origination charges, and the total discount points of the loan.

CFPB is looking to get feedback from the industry and other interested parties about the expansion of the HMDA data reporting requirements later this year. Under HMDA, lenders are required to record the number of loans approved and rejected, a loan’s purpose (such as a refinancing), the sex, race and ethnicity of applicants and the interest rate spread, among other items. But the Dodd-Frank Act required the bureau to begin adding new data collection points, including total points and fees, the term of the loan, the length of any teaser interest rates and the borrower’s age and credit score. CFPB would goi beyond that, potentially asking lenders whether they considered a loan for QM status and to further explain if they rejected a loan. CFPB officials said they are also mindful of the data collection burden this would impose on lenders. The agency said it is considering ways to ease the compliance burden by aligning HMDA data collection with the Uniform Loan Delivery Dataset that lenders use to deliver loans to Fannie Mae and Freddie Mac.

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