CFPB Calls for Feedback

Adam Witmer
Regulatory Update

Yesterday, the CFPB announced that it is issuing “call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers.”  This call comes just weeks after CFPB management changed where Mick Mulvaney was appointed by President Trump to temporarily run the CFPB after the departure of long-time director Richard Cordray.   The CFPB publication states that the Bureau will...

Payday Rule and CFPB Statement

Adam Witmer
Regulatory Update

On January 16, 2017, the CFPB issued a statement that they intend to reconsider the final Payday Rule which was originally issued on October 5, 2017.  This publication, which came on the effective date of the final rule, explains that the reconsideration will occur through an official rulemaking process.  The CFPB also discusses how compliance with the final rule will be affected by...

HMDA Head Scratcher - The New HMDA Hierarchy

Adam Witmer
HMDA

As is the case with new regulations, we are often left scratching our heads as to why a rule is done the way it is.  For those of you that are HMDA reporters, I’m sure you can relate with the 2018 changes that are now upon us.  In particular, one HMDA head scratcher is the new HMDA hierarchy for reporting the loan purpose.   This article explains why the CFPB made the change.

Demographic Information Under Reg B & HMDA

Adam Witmer
Compliance Management

On the surface, collecting and recording demographic information (DI) seems fairly straightforward and simple.  One would assume that requesting and collecting the ethnicity, race, and gender of an applicant wouldn’t be terribly difficult.  Besides, the requirement to collect government monitoring information (GMI) has been around for nearly 40 years (though the regulators just recently changed the reference from GMI to DI).  Why is it then that so many financial institutions still struggle with...

FDIC Releases Monthly List of CRA Evaluations

Adam Witmer

By law, each regulatory agency is required to publish a list of financial institutions examined for Community Reinvestment Act (CRA) compliance.  If you are a CRA Officer, this is both a blessing and a curse.  First of all, you don't necessarily want the world to see your exam.  However, reading exams from other banks can be a fantastic tool to help you with your job.  In fact, I believe that reading other...

Loan Exception Tracking

Adam Witmer
Compliance Management, Fair Lending

Loan exceptions occur any time a loan file does not meet the established standards for a financial institution.  Lenders typically have guidelines they must follow, and when those guidelines are not exactly adhered to, an exception occurs.  There are typically two types of loan exceptions: 1) Policy exceptions and 2) underwriting exceptions.  Policy exceptions occur when...

HMDA Enforcement for 2018 Data

Adam Witmer
Regulatory Update, HMDA

On December 21, 2017, the CFPB (as well as the OCC and FDIC) released a statement announcing the Bureau's intentions for enforcement with respect to errors for data collected in 2018 and reported in 2019 under the Home Mortgage Disclosure Act (HMDA).  Per the release, "the Bureau does not intend to...

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