By: Michael Flynn
March 11, 2020
“The Home Mortgage Disclosure Act (HMDA) 2015 Rule revisions promulgated by the Consumer Financial Protection Bureau (CFPB) expressly set forth when residential multifamily property lenders must collect and report data under HMDA.
The 2015 Rule set forth what data must be reported by multifamily lenders. In May 2019, the CFPB issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comments about key obligations under the 2015 Rule. If enacted, the types of rule changes discussed in the ANPR would either eliminate or reduce multifamily lenders HMDA reporting obligations.
Either of these possible changes would cause elimination of multifamily lenders’ HMDA obligations, or, at the least, significantly reduce such lenders’ obligations. So what are the current 2015 Rule’s multifamily lender reporting obligations and what impact might changes suggested by the ANPR have?”
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