Home Mortgage Disclosure Act (HMDA)/Reg 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 ICE Mortgage Technology, 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.
Disclaimer: These questions and answers are provided based on those received during webinars provided by the ICE Mortgage Technology Compliance Department, and those submitted to ICE Mortgage Technology directly by you. This content is intended for general information purposes with the goal of assisting ICE Mortgage Technology’s customers and non-customers, in complying with the future provisions under Regulation C (HMDA). This information is provided as a courtesy to ICE Mortgage Technology’s customers and ICE Mortgage Technology makes no representation or warranty regarding the accuracy of the information set forth herein, and you may not rely on this information to ensure your company’s compliance with Regulation C (HMDA). This publication should not be construed as legal advice or opinion on any specific facts or circumstances, including the application of the HMDA regulations. You are advised to consult your own compliance staff or attorney regarding your specific residential mortgage lending questions or situation to ensure your compliance with all applicable laws and regulations.