Review what the amendment that S.2155 would make to the HMDA for insured banks and insured credit unions that satisfy certain conditions.
In this white paper, our author, Richard Andreano addresses what the amendment would and would not do. He discusses that the amendment would not exempt any institution from the Equal Credit Opportunity Act, the Fair Housing Act or any other substantive fair lending law. He also covers that the amendment would exempt small-volume mortgage lenders from the expanded HMDA data reporting requirements that became effective on January 1, 2018, if they met certain conditions. Read this white paper for what those conditions are, as well as what the main impact from the S.2155 amendment would be.
Practice leader, Mortgage Banking Group, Ballard Spahr LLP
Fellow, American College of Consumer Financial Services Lawyers
Chambers USA: America's Leading Lawyers for business, banking and finance: financial services regulation: consumer finance (compliance), national ranking, 2014 to 2017
Wrote MBA Compliance Essentials Loan Originator Compensation Resource Guide™, published by the Mortgage Bankers Association
Co-wrote, MBA Compliance Essentials TILA/RESPA Integrated Disclosure TRID Rule Resource Guide™, published by the Mortgage Bankers Association
Editor-in-chief, Mortgage Finance Regulation Answer Book 2011-2012, published by the Practising Law Institute; author of chapters on the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Home Mortgage Disclosure Act, and the Real Estate Settlement Procedures Act; and co-author of the Equal Credit Opportunity Act and Truth in Lending Act chapters
Counsels clients on residential mortgage regulatory matters, including ability to repay, TILA/RESPA integrated disclosure (TRID) rule, CFPB and other regulator supervision and examination, UDAAP and other Dodd-Frank matters
Frequent speaker and author on mortgage industry issues