The New HMDA Rule’s Expanded Ethnicity and Race Categories
Author: Michael Flynn.; Kimberly Monty Holzel.
Source: Volume 31, Number 02, Winter 2018 , pp.27-29(3)
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Abstract:
HMDA’s new rule provides that when applicants fill out the requested ethnicity, race, and sex information, they can supply their own descriptions by writing in an unlimited number of self-identified subcategories under race and ethnicity. The financial institution, however, may report only a total of five categories and subcategories combined. The authors describe the rule, the problems it creates for financial institutions, and the open questions on which the CFPB should provide further guidance. *This article available for download for journal subscribers only; no pay-per-article option is available.Keywords: Consumer Financial Protection Bureau (CFPB); Home Mortgage Disclosure Act (HMDA); HMDA Rule expansion; 12 CFR 1003; government monitoring information (GMI) requirements; Regulation C
Affiliations:
1: Goodwin Procter LLP; 2: Goodwin Procter LLP.