Consumer Financial Protection Bureau | 2021 – Supervisory Highlights

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Treliant Takeaway:

Treliant’s Corporate & Regulatory Compliance practice stands ready to assist you as you navigate ever-changing regulations and resulting consumer lending requirements.  From transaction level through transformation, Treliant’s well-seasoned professionals can help.  As Fair Lending and HMDA-related regulatory enforcement continues to expand, now is the time to document and test to ensure that your actions and outcomes are compliant. Know the story your data tells!

Consent Order Highlights:

On June 29, 2021, the Consumer Financial Protection Bureau released its Summer 2021 Supervisory Highlights which outlines, among other things, supervisory observations trends related to fair lending & HMDA, most notably from the Bureau’s 2018 and 2019 Home Mortgage Disclosure Act (HMDA) Examinations.

The Bureau’s 2018 and 2019 HMDA examinations were focused on all mortgage originators responsible for compliance with HMDA, including depository and non-depository institutions. During examinations that resulted in significant errors, Examiners identified that a deficient Compliance Management System (CMS) for the institution was the root cause of the violations. In addition, institutions had significant errors related to data mapping from the institutions’ loan origination systems. Significant errors related to the following data points were identified as a result of the examinations:

  • Data Mapping: Credit Scoring Model, Rate Spread, and Debt-to-Income Ratio
  • Misinterpretation of Regulation C (HMDA): Age of Applicants and Co-Applicants, Origination Charges, Discount Points, and Lender Credits

As a result of these examinations, institutions were required to review their LAR data for accuracy and submit an updated LAR, as well as make significant updates to their HMDA CMS, including policies and procedures, board and management oversight and training.