CoreLogic has released The Home Mortgage Disclosure Act: Foundation for a Sound Housing Market, the third white paper in a series which addresses the implications of new and revised federal mortgage finance industry regulations. In this edition, the nearly 40-year-old Home Mortgage Disclosure Act (HMDA) is reviewed in the context of the new regulatory environment and what that might mean for future changes to the law.
Key insights provided in the white paper include:
►An understanding of what the law is and what it is not, including how HMDA is largely viewed as a tool designed to be used in tandem with existing fair housing laws.
►The potential impact of transferring HMDA supervision and enforcement from the Federal Reserve Board to the Consumer Financial Protection Bureau (CFPB) and its formally initiated rulemaking process under Regulation C (HMDA) in February 2014.
►Analysis of the additional data points proposed beyond the existing statute deemed to be useful for regulatory purposes including debt-to-income, combined loan-to-value ratios, origination charges and interest rate received.
►Discussion of how the evolution of HMDA may impact the mortgage finance industry. In particular, the unintended creation of default lending standards based on expanded data capture requirements, despite the law not being designed to serve that function.