ABA Regulatory Compliance Inbox: If my bank reduces the amount of a customer’s HELOC, are we required to provide an adverse action notice?
And: Must banks include a printed version of their “HMDA Disclosure Statement” in their CRA public file?
And: Must banks include a printed version of their “HMDA Disclosure Statement” in their CRA public file?
And it permissible for a bank to purchase an email list from a third party to send out email marketing materials to non-customers?
The Federal Financial Institutions Examination Council’s 2023 Guide to HMDA Reporting is now available for download. The 2023 guide focuses on HMDA data submissions due March 1, 2024, and offers the most official source for assisting institutions in their HMDA reporting.
And what qualifies as ‘principal shareholders,’ ‘directors’ and ‘executive officers’ under Regulation O?
With uncertainty the rule, the best advice is to have banks’ change-management processes ready for whatever comes.
Lenders need assurances regarding legal and examination risk plus time for lenders to install or refine HMDA systems and achieve compliance.
CFPB said banks may need time to implement or adjust policies, procedures, systems and operations to comply with reporting obligations.
A federal judge recently moved to vacate CFPB regulations that expanded the number of small-volume lenders deemed exempt from Home Mortgage Disclosure Act reporting requirements. I
The share of mortgages originated by nonbanks continues to climb, accounting for 63.9% of home-purchase loans, up from 60.7% in 2020.
What would my bank report if instead of income it based the credit decision on the assets of the borrower?