CFPB Warns Mortgage Services to Prepare for Homeowners Needing Assistance

Adam Witmer
Regulatory Update

On 4/1/2021, the CFPB warned mortgage servicers to take all necessary steps now to prevent a wave of avoidable foreclosures this fall. In their release, the CFPB explained that millions of homeowners currently in forbearance will need help from their servicers when the pandemic-related federal emergency mortgage protections expire this summer and fall, and that servicers should dedicate sufficient resources and staff now to ensure they are prepared for a surge in borrowers needing help. The CFPB explained that they will closely monitor how servicers engage with borrowers, respond to borrower requests, and process applications for loss mitigation.

CFPB Announces Availability of 2020 HMDA Data

Adam Witmer
BSA

On 3/31/21, the CFPB announced that the HMDA LAR data for 2020 were were published on the Federal Financial Institutions Examination Council’s HMDA Platform for approximately 4,400 HMDA filers. Later this year, the 2020 HMDA data will be available in other forms to provide users insights into the data, including a nationwide loan-level dataset. In their release, the CFPB explains that dataset will provide all publicly available data from all HMDA reporters, aggregate and disclosure reports with summary information by geography and lender, and the HMDA Data Browser to allow users to create custom datasets and reports. The Bureau will also publish a Data Point article highlighting key trends in the annual data.

FinCEN Begins Changes to Beneficial Ownership Reporting

Adam Witmer
BSA, Regulatory Update

On 4/1/21, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a wide range of questions related to the implementation of the beneficial ownership information reporting provisions of the Corporate Transparency Act (CTA). In their release, FinCEN explains that this ANPRM is the first in a series of regulatory actions that FinCEN will undertake to implement the CTA, which is included within the Anti-Money Laundering Act of 2020 (AML Act). The AML Act is part of the FY 2021 National Defense Authorization Act, which became law on January 1, 2021.

NCUA Chairman Named Chairman of FFIEC

Adam Witmer
Regulatory Update

On 4/1/2021, the FFIEC announced that Todd M. Harper, Chairman, National Credit Union Administration (NCUA), was named Chairman of the Federal Financial Institutions Examination Council (FFIEC). His two-year term runs from April 1, 2021, through March 31, 2023. Mr. Harper became the NCUA’s twelfth Chairman on January 20, 2021, and has been making statements over the last year that imply potential changes to how the NCUA will regulate consumer protection going forward.

Revised HMDA Getting It Right Guide for 2021

Adam Witmer
HMDA, Regulatory Update

On 3/31/2021, the FDIC announced that the Federal Financial Institutions Examination Council (FFIEC) had issued the 2021 edition of A Guide to HMDA Reporting: Getting It Right! for Home Mortgage Disclosure Act (HMDA)-related data collected in 2021 and reported in 2022. This longstanding compliance resource has regularly been used by financial institutions as a “go-to” HMDA resource as it can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.

FDIC Consumer Compliance Supervisory Highlights March 2021 Edition

Adam Witmer
Regulatory Update

On 3/31/2021, the FDIC issued a release (FIL-22-2021) to explain that the latest edition of their Consumer Compliance Supervisory Highlights had been published. The purpose of this publication is to provide insight regarding the FDIC’s consumer compliance supervisory activities and provide a high-level overview of consumer compliance issues identified in 2020 through the FDIC’s supervision of state non-member banks and thrifts. Topics include a summary of the FDIC’s supervisory approach in response to COVID-19, supervisory observations related to consumer protection laws, examples of practices that may be useful to institutions in mitigating risks, regulatory developments, and consumer compliance resources.

Request for Information on AI Use

Adam Witmer
Regulatory Update

On 3/29/21, the Federal Reserve, CFPB, FDIC, NCUA, and OCC jointly released a “Request for Information” to gather insight on financial institutions’ use of artificial intelligence (AI). In their release, the agencies explain that they are seeking information from the public on how financial institutions use AI in their activities, including fraud prevention, personalization of customer services, credit underwriting, and other operations.

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