(OnlineEd – Portland, OR) – To date, the CFPB has conducted HMDA (Home Mortgage Disclosure Act) reviews at dozens of mortgage lenders, both bank and nonbank. In the wake of these audits, the Bureau has issued an industry wide bulletin to help banks and nonbanks realize the importance of accurate reporting, effective HMDA compliance management systems and adequate employee training.
A copy of the bulletin can be viewed by clicking the Resources tab at www.InlineEd.com and then scrolling down to October 9, 2013 CFPB Bulletin on HMDA Compliance Management.
The Bureau reviews the accuracy of HMDA data and assesses compliance programs as part of its supervision of both banks and nonbanks.
The bulletin also announces the release of the CFPB’s HMDA Resubmission Schedule and Guidelines, which lists the error thresholds that CFPB examination teams will use to determine when institutions should correct and resubmit their HMDA data. The CFPB’s new HMDA Resubmission Schedule and Guidelines apply to HMDA reviews that begin on or after Jan. 18, 2014.
By issuing this bulletin today, the Bureau is putting the industry on notice about the integrity of mortgage information. Specifically, the bulletin:
- Discusses components of an effective HMDA compliance management system. The bulletin suggests common elements of an effective compliance system, which include employee training, internal audits to test and evaluate information accuracy, and assigning responsibility for timely and accurate reporting of the data.
- Details factors the CFPB may consider when evaluating whether to pursue a public enforcement action for HMDA violations. The CFPB may consider various factors when determining whether to pursue a public enforcement action, including: the size of the bank or nonbank’s mortgage lending activity; the error rate; the history of previous HMDA supervisory activity, including the history of any violations; and whether the institution self-identified or self-corrected any errors. These factors, along with those listed in the Dodd-Frank Act, will be considered when determining the appropriate size of any civil penalty that the Bureau seeks.
A copy of the bulletin can be viewed by clicking the Resources tab at www.InlineEd.com and then scrolling down to October 9, 2013 CFPB Bulletinon HMDA Compliance Management.
For more about OnlineEd and HMDA training visit www.OnlineEd.com or www.InlineEd.com or call Joseph Mikkelson at 1.866.519.9597. For more about the CFPB, please visit their web site http://www.consumerfinance.gov/
Jeff Sorg is a co-founder of OnlineEd®, an online real estate, mortgage broker, and vocational school founded in 1997, where he also serves as Chief Executive Officer, and School Director. Sorg holds vocational and post-secondary school instructor licenses in several states and has authored numerous real estate continuing education and pre-licensing courses and has been awarded the International Distance Education Certification Center’s CDEi Designation for distance education. Memberships include ARELLO (Association of Real Estate License Law Officials), the National Association of REALTORS®, Oregon Association of REALTORS®, and Portland Metro Association of REALTORS®. Awards and service include REALTOR® Emeritus in the National Association, Life Member award in Portland Metro Association and Chairperson of the Oregon Real Estate Forms Committee.
OnlineEd® provides real estate, mortgage broker, insurance, and contractor pre-license, post-license, continuing education, career enhancement, and professional development and designation courses over the Internet.