CFPB Proposes HMDA Clarifications

In case you missed it, the CFPB issued a proposal last week (which consists of about 150 bonus pages of HMDA Kevin3goodness) to make some corrections and clarify changes to the HMDA final rule that will be shaking up the compliance world for the next couple of years.

The proposal includes:

  • CFPB plans for a geocoding tool that can be relied on for census tract information;
  • Clarifications for certain terms, such as temporary financing and automated underwriting system; and,
  • The establishment of some transition rules for two data points (loan purpose and the loan originator unique identifier) for certain purchased loans.

Under the proposal, loans to a person exclusively to construct a dwelling for sale would be considered temporary financing.  In other words, builder loans or spec loans would not be reportable under HMDA.  That’s good news!

Comments are due 30 days after the proposal is published in the Federal Register.  Stay tuned!

Kevin Edwards

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