CFPB Adopts New Rule Expanding Reporting Requirements Under HMDA

On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) released a final rule that expands the scope of mandatory reporting under the Home Mortgage Disclosure Act (HMDA). The new rule, which will be implemented in phases between 2017 and 2020, may prove costly for mortgage lenders.

Originally enacted in 1975, HMDA requires lenders to collect and disclose specific data about their mortgage lending practices. In 2010 as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), Congress instructed the CFPB to revise Regulation C, the regulation implementing HMDA, in order to increase transparency in the mortgage industry.  This new 797-page rule, however, significantly exceeds the scope of the required Dodd-Frank amendments and relies heavily on the CFPB's discretionary regulatory authority.