The American Bankers Association has published a free, members-only staff analysis of the Consumer Financial Protection Bureau’s recent proposal to provide flexibility for lenders around the collection of applicants’ demographic data under the Home Mortgage Disclosure Act (Regulation C) and the Equal Credit Opportunity Act (Regulation B). The proposal would harmonize Reg B requirements for collecting race and ethnicity information with changes to Reg C which take effect Jan. 1, 2018.
Specifically, the proposed amendments would permit borrowers to self-identify using disaggregated racial and ethnic categories (as required by recent changes to Reg C). They would also remove the outdated 2004 Uniform Residential Loan Application as a model form, and give creditors not subject to HMDA reporting requirements the option to collect race and ethnicity data in certain instances where it is not required. Comments on the proposal are due May 4. For more information, contact ABA’s Rob Rowe.