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ARTICLE · 28 OCTOBER 2015

HOLY HMDA! CFPB Finalizes Changes To Home Mortgage Disclosure Rule

Morrison Foerster
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On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA).

United StatesFinance and Banking
Leonard Chanin
Leonard Chanin
Angela Kleine
Angela Kleine
Ryan Richardson
Ryan Richardson
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On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to Regulation C in four broad areas: (1) the types of institutions required to collect and report HMDA data; (2) the types of transactions and applications subject to collection and reporting requirements; (3) the data that must be collected and reported; and (4) the method and frequency of reporting data and making data available to the public.

This alert provides a high-level summary of the major changes to Regulation C in each of these four areas. We are continuing to examine the 796-page (and 560-footnote!) issuance, and we plan to provide a more detailed description and analysis following that review.

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