As previously reported, on October 15, 2015, the CFPB released a final rule (the “Rule”) amending Regulation C, 12 C.F.R part 1003, which implements HMDA. Shortly thereafter, we published a high-level summary of the Rule, describing the major changes to Regulation C across four broad areas:
- Covered institutions, i.e., the types of institutions required to collect and report HMDA data;
- Covered transactions, i.e., the types of transactions and applications subject to collection and reporting requirements;
- Loan-level data, i.e., the data about transactions that institutions must collect and report; and
- Reporting and disclosure, i.e., the method and frequency of reporting data and making that data available to the public.
This follow-up alert digs deeper into the Rule, while continuing to track its changes according to the four areas listed above. We give particular attention to some of the less-than-intuitive intricacies of the coverage tests for institutions and transactions, as well as to the new and modified loan-level data requirements.
Read our client alert.