CFPB Proposes Revisions to HMDA and Collection of Additional Data
by: Anna DeSimone
February 7, 2014, the Consumer Financial Protection Bureau (CFPB) began the process of revising the Home Mortgage Disclosure Act (HMDA) rules to require lenders to collect and report several new data elements. Some of these new data elements are specifically required under Dodd-Frank.
The Bureau is also considering requiring some additional data elements to improve information reported about the residential mortgage market and to help the public and financial regulators better understand borrower access to credit.
As a first step in the rulemaking process, the CFPB is convening a panel of small businesses to seek feedback on potential changes to mortgage information reported under the Home Mortgage Disclosure Act (HMDA). The CFPB is seeking to improve the quality of the information submitted by lenders, while streamlining the reporting process to reduce the burden on lenders.
The CFPB is also considering changes to the collection rules to streamline reporting and improve data entry. Finally, it is also considering revising the reporting thresholds so all banks and non-banks report if they make 25 or more mortgage loans in a year.
New Information Required By Dodd-Frank
The Dodd-Frank Act specifically directed the CFPB to expand HMDA to include additional information. The CFPB will ask for small business feedback on these new requirements, including:
- Total points and fees, and rate spreads for all loans
- Age and credit score
- Riskier loan features including teaser rates, prepayment penalties, and non-amortizing features
- Lender information, including a unique identifier for the loan officer and the loan
- Property value and improved property location information
Additional Data Points under Consideration
The Dodd-Frank Act authorizes the Bureau to include additional data points in HMDA. The CFPB is asking
the Small Business Review Panel to also provide feedback on potential proposals under consideration, including:
- Mandatory reporting of denial reasons
- Debt-to-Income (DTI) ratio
- Qualified Mortgage status of loan
- Combined loan-to-value (CLTV) ratio
- Automatic underwriting systems results
- Additional points and fees information
- Affordable housing programs
- Manufactured housing data
About the Author
Anna DeSimone is President and Founder of Bankers Advisory, Inc. She can be reached at anna@bankersadvisory.com
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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