Home Mortgage Disclosure Act (HMDA)/Reg C

After the effective date of the rule on Regulation C, this will require my organization to file a Loan Application Register (LAR) for the first time. Are there resources available to assist us in understanding the requirements under Regulation C?

There are many available resources (or will be prior to the effective dates with the rule) issued by the CFPB, and potentially the Federal Financial Institutions Examination Council (FFIEC) and other regulatory agencies, as well as industry vendors (such as Ellie Mae, law firms, vendors providing solutions available via LAR delivery software, etc.). For instance, the CFPB has already provided a number of resources, such as: the Small Entity Compliance Guide; a chart identifying reportable fields; a chart identifying when fields are reported as not applicable; a chart regarding institutional applicability; a timeline chart, and other resources.

These can be found presently at: http://www.consumerfinance.gov/regulatory-implementation/hmda and may be augmented by additional tools prior to implementation by the CFPB. In addition a web site has already been established for industry filers and the general public at: www.consumerfinance.gov/hmda which is also where the already expected instructions replacing the current Appendix A (which will be removed and reserved on January 1, 2019) will be found when published.