Mortgages, Reporting Requirements, Consumer Financial Products

Senate Passes House Version of Trigger Leads Bill

Ballard Spahr LLP on 8/4/2025

As previously reported, both the House and Senate passed bills to ban “trigger leads,” except in limited circumstances, although the versions of the bills that were previously passed are slightly different. The one difference...more

2024 HMDA Modified Loan Application Data Published

Ballard Spahr LLP on 4/8/2025

The CFPB has announced that Home Mortgage Disclosure Act (HMDA) Modified Loan Application Register (LAR) data for 2024 are now available on the Federal Financial Institutions Examination Council’s (FFIEC) HMDA Platform for...more

CFPB will reportedly continue to update Average Prime Offer Rate tables

Orrick, Herrington & Sutcliffe LLP on 2/14/2025

On February 11, it was reported that, despite the temporary halt in the CFPB’s operations, the Bureau’s tables for the Average Prime Offer Rate (APOR) will continue to be updated weekly by the CFPB. A Bureau spokesperson...more

FHA seeks comments on the proposed establishment of the optional reimbursement claim alternative mortgagee letter

Orrick, Herrington & Sutcliffe LLP on 1/13/2025

Recently, FHA’s Office of Single Family Housing included on its “Drafting Table” a request for stakeholder feedback on both a draft Mortgagee Letter establishing the Optional Reimbursement Claim Alternative Option (“ORCA”)...more

FHA publishes revised cyber incident reporting requirements

Orrick, Herrington & Sutcliffe LLP on 12/18/2024

On December 2, the FHA issued Mortgagee Letter 2024-23, outlining revised requirements for reporting cyber incidents by FHA-approved mortgagees. According to the letter, the revisions aim to align FHA reporting requirements...more

Filing Instruction Guide for 2025 HMDA data submission is released

Ballard Spahr LLP on 9/27/2024

The CFPB recently announced that the Filing Instruction Guide (FIG) for the submission of Home Mortgage Disclosure Act (HMDA) data collected in 2025 is now available. The FIG, issued by the Federal Financial Institutions...more

Highlights from the CFPB’s Spring 2024 Semi-Annual Regulatory Agenda

Troutman Pepper Locke on 7/22/2024

The Consumer Financial Protection Bureau (CFPB or Bureau) recently released its semi-annual regulatory agenda, outlining its planned rulemaking initiatives. The CFPB releases regulatory agendas twice a year in voluntary...more

CFPB Releases Mortgage Servicing Report on Borrower Experiences During the COVID-19 Pandemic

Ballard Spahr LLP on 7/16/2024

The complexity of loss mitigation programs designed to assist distressed mortgage borrowers during the COVID-19 pandemic may have been too daunting for many borrowers to seek help, the CFPB said, in a report released last...more

CFPB Issues Proposed Rule Amending Mortgage Servicing Rules

Ballard Spahr LLP on 7/16/2024

The CFPB recently issued its long-awaited proposed rule amending the mortgage servicing rules under Regulation X, with a focus on streamlining and expanding the loss mitigation procedures and foreclosure protections. The...more

Possible… but Practical? HUD’s New 12 Hour Cyber Incident Reporting Requirement for FHA-Approved Mortgagees

Wyrick Robbins Yates & Ponton LLP on 7/10/2024

On May 23, 2024, the U.S. Department of Housing and Urban Development (“HUD”) issued requirements, effective immediately, for all FHA-approved mortgagees to report certain cyber incidents to HUD within 12 hours of detection....more

CFPB Files $3.95M Proposed Order to Settle HMDA Lawsuit Against Florida-Based Mortgage Company

Sheppard Mullin Richter & Hampton LLP on 6/24/2024

On June 18, the CFPB filed a proposed final judgment that would require a Florida-based nonbank mortgage originator and servicer to pay a $3.95 million civil money penalty and implement corrective actions requiring the...more

FHA Requiring Reporting of Significant Cybersecurity Incidents

Ballard Spahr LLP on 5/28/2024

In Mortgagee Letter 2024-10, FHA announced a requirement for FHA approved lenders to notify the U.S. Department of Housing and Urban Development (HUD) of Significant Cybersecurity Incidents. The Mortgagee Letter, which is...more

FFIEC releases 2022 HMDA data

Orrick, Herrington & Sutcliffe LLP on 3/27/2023

On March 20, the CFPB announced the release of the 2022 HMDA modified loan application register (LAR) data. The LAR data, available on the Federal Financial Institutions Examination Council’s HMDA platform, contains modified...more

CFPB Issues Reminder of New Threshold for Reporting HMDA Open-End Lines of Credit Data

Goodwin on 11/22/2021

In This Issue. The Consumer Financial Protection Bureau (CFPB) reminded institutions of a new threshold for reporting Home Mortgage Disclosure Act data about open-end lines of credit; the Financial Crimes Enforcement Network...more

FFIEC Announces Release of 2019 HMDA Data

Ballard Spahr LLP on 6/26/2020

On June 24, 2020, the Federal Financial Institutions Examination Council (FFIEC) announced the release of the 2019 Home Mortgage Disclosure Act (HMDA) data. ...more

CFPB Raises HMDA Reporting Thresholds

Ballard Spahr LLP on 4/19/2020

The CFPB recently issued a final Home Mortgage Disclosure Act (HMDA) rule to increase the threshold to report closed-end mortgage loans from 25 to 100 originated loans in each of the prior two years, and to increase the...more

2020 HMDA Guide Issued

Ballard Spahr LLP on 2/14/2020

The Federal Financial Institutions Examination Council (FFIEC) recently issued the 2020 edition of the Guide to HMDA Reporting: Getting It Right! (2020 Guide)....more

CFPB Updates HMDA Guide

Ballard Spahr LLP on 1/27/2020

As previously reported, in October 2019 the CFPB issued a final rule under the Home Mortgage Disclosure Act (HMDA) to...more

New York Issues Final Mortgage Servicing Regulations

Ballard Spahr LLP on 1/27/2020

On December 18, 2019, the New York Department of Financial Services (DFS) issued its Final Regulations detailing the business conduct rules for mortgage loan servicers. ...more

CFPB Issues Final HMDA Rule (2019 Update)

Ballard Spahr LLP on 10/11/2019

The CFPB recently issued in final form two elements of a May 2019 Home Mortgage Disclosure Act (HMDA) proposed rule. As previously reported, the May 2019 proposal would...more

A Little More COFI

Ballard Spahr LLP on 8/12/2019

As previously reported, late last year the Federal Home Loan Bank of San Francisco (FHLB of San Francisco) announced that it would discontinue publishing the 11th District Weighted Average Cost of Funds Index (COFI) after the...more

CFPB Reopens HMDA Proposed Rule Comment Period

Ballard Spahr LLP on 8/1/2019

The CFPB recently announced that it is reopening the comment period for the May 2019 Home Mortgage Disclosure Act (HMDA) rule proposal. Comments on certain aspects of the proposal, addressed below, are due by October 15,...more

HMDA Proposed Rule Comment Period

Ballard Spahr LLP on 6/11/2019

As previously reported, in May 2019 the CFPB issued both a proposed rule to modify the existing Home Mortgage Disclosure Act (HMDA) rule and an advance notice of proposed rulemaking seeking comment on additional potential...more

Mortgage lender fined for alleged HMDA violations

Hogan Lovells on 6/11/2019

On 5 June 2019 the Consumer Financial Protection Bureau (CFPB) announced its consent order (consent order) with a large mortgage lender (the company) for allegedly reporting erroneous sex, race, and ethnicity Home Mortgage...more

CFPB Issues Home Mortgage Disclosure Act Reference Chart

Ballard Spahr LLP on 2/5/2019

The CFPB recently issued A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2019. As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act created an exemption...more

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