In these difficult times, the Consumer Financial Protection Bureau (CFPB) is providing flexibility for mortgage lenders by temporarily waving the requirement to report Home Mortgage Disclosure Act (HMDA) and Regulation C data on a quarterly basis.
However, the CFPB stresses that lenders should continue to collect HMDA and Regulation C data as required, in anticipation of reporting by the end of the year. The agency says it will notify lenders when it is time to resume quarterly HMDA data submissions.
In addition to waving quarterly HMDA reporting requirements during the coronavirus crisis, the CFPB has announced that it is willing to work with affected financial institutions in scheduling examinations and other supervisory activities to minimize disruption and burden.
When conducting examinations and other supervisory activities and in determining whether to take enforcement action, the bureau will consider the circumstances that entities may face as a result of the COVID-19 pandemic and will be sensitive to good-faith efforts demonstrably designed to assist consumers.
“As consumers seek temporary relief from lenders, the pandemic is impacting the operations of financial companies that are eager to help their customers during this unprecedented time,” says Kathleen L. Kraninger, director of the CFPB, in a statement “Our actions today are temporary and targeted to support consumers by allowing financial companies to focus their resources on assisting consumers.
“The bureau, along with our state and federal partners, have released prior guidance encouraging financial institutions to work constructively with borrowers and other customers affected by COVID-19 to meet their financial needs,” Kraninger says. “We will continue to issue additional guidance and policies to facilitate the ongoing collaborative relationship between companies and their customers during this time.”
In a separate statement, Bob Broeksmit, president and CEO of the Mortgage Bankers Association (MBA), says the association appreciates “the suspension of quarterly HMDA reporting, working to limit examination burdens, and the commitment to consider these unique circumstances in subsequent supervision.”
“These measures will help our members continue to direct their focus to serving their customers’ needs during this pandemic,” Broeksmit says. “MBA looks forward to continuing to work with the bureau and others in determining additional solutions that will benefit consumers in these times.”
In addition to the aforementioned actions, the CFPB has also provided relief to credit card issuers by delaying the reporting of certain information under the Truth in Lending Act, Regulation Z, and Regulation E.
This includes the annual submissions concerning agreements between credit card issuers and institutions of higher education; quarterly submission of consumer credit card agreements; collection of certain credit card price and availability information; and submission of prepaid account agreements and related information.