The Home Mortgage Disclosure Act: Common Compliance Challenges
Author: Sherry-Maria Safchuk.; Frida Alim.
Source: Volume 34, Number 09, September 2018 , pp.101-112(12)
Abstract:
In their discussion of common challenges in HMDA reporting, the authors focus on transactions with multiple parties, business purpose loans, required reportable actions, and automated underwriting systems. They also discuss the combined loan-to-value ratio, and the collection and reporting of demographic data. They conclude by describing how the Bureau of Consumer Financial Protection evaluates the compliance management systems of the institutions it supervises.Keywords: Home Mortgage Disclosure Act (“HMDA”); Regulation C
Affiliations:
1: Buckley Sandler LLP; 2: Buckley Sandler LLP.