Last week, the CFPB released a new compliance guide to accompany its October 15, 2015, final rule amending Regulation C, which implements the Home Mortgage Disclosure Act. As discussed in two previous alerts – available here and here – the final rule makes sweeping changes to the types of institutions and transactions covered by Regulation C, and it vastly expands the universe of data about transactions that institutions must collect and report.
The CFPB describes the compliance guide as a "plain language" resource designed to make the content of the rule "more accessible for industry constituents, especially smaller businesses with limited legal and compliance staff." If length is any judge, the 108-page guide certainly is easier to navigate (and carry) than the 796-page final rule.
Along with the compliance guide, the CFPB posted three new charts to its HMDA resources page. The first summarizes the circumstances in which certain data points may be reported as "not applicable." The second and third summarize the changes to institutional coverage that will become effective Jan. 1, 2017, and Jan. 1, 2018, respectively.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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