Archive: HMDA
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Dec 15, 2009
No CommentsHMDA Data: Wrap it Up For the Holidays
In the spirit of the holiday season, what if you thought of your HMDA data as the ultimate gift? In a way, your HMDA data is a gift that keeps on giving. Every year your HMDA data provides valuable information about your institution’s lending practices. Your gift list includes regulators, the Board, your community, and...
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Oct 23, 2009
No CommentsMore, or Less Consumer Regulation? More!
By Edward B. Kramer, Executive VP, Regulatory Programs As we all know by now, the House Financial Services Committee voted 39 to 29 on Thursday to approve legislation to create a consumer financial protection agency, a key priority in the Obama administration’s regulatory reform plan. The bill would remove from the federal banking and thrift agencies...
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May 27, 2009
No CommentsRegulation Z vs. Regulation C – What will it tell your examiners?
The industry continues to talk about the interplay between the new higher priced mortgages under Regulation Z and the HMDA reporting requirement under Regulation C. These are two areas of concern. First, the reportable rate spreads that are filed on your HMDA report will be an easy starting point for examiners to find higher priced...
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May 18, 2009
No CommentsRisk Management
While attending the MBA’s Legal Issues And Regulatory Compliance Conference last week, several of the speakers spoke about controlling risk throughout the process. Legal and Compliance should be involved in the risk management process from beginning to end. The Legal and Compliance department has the global perspective on risk while the business line has a...
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Feb 24, 2009
No CommentsReg Z and Reg C Changes Take Effect October 1: Banks Prepare Now for Operational Impact
By Amy Downey Banks are acting now to ready systems and update policies and procedures in advance of the October 1, 2009 effective date. October 1 will mark a significant change in the Regulation C reportable rate spread and the addition of a new lower predatory lending threshold under Regulation Z (Higher Priced mortgages). In...
