As we ring in the new year, it is helpful to recap what has happened in 2021 on three different fronts: HMDA, fair lending, and CRA (the Community Reinvestment Act). I count eight important developments. These are listed in no particular order below:
1. HMDA Filing Instruction Guide (FIG) updates
The most recent revision to the 2022 FIG came in October 2021. There are some new edit checks.
2. A new threshold for reporting open-end transactions in HMDA goes into effect on January 1, 2022.
More institutions will be reporting open-end transactions in 2022. See this Final Rule.
3. The most recent guidance for large quarterly HMDA reporters was published in September 2021.
The CFPB in March 2020 had allowed large HMDA reporters to delay quarterly reporting, but in 2021 quarterly reporting began.
4. The 2020 HMDA Snapshot data were released in June 2021.
Generally low interest rates led to a boom in refinancings and home purchase lending. This, combined with widespread discussion around equal access to credit, created a lot of interest in the HMDA data.
5. In October 2021, the Combatting Redlining Initiative was announced by DOJ, CFPB, and OCC.
Relatedly, new leadership at DOJ and CFPB was confirmed by the US Senate in March and September 2021, respectively.
6. Also in October 2021, the CFPB published in the Federal Register a Proposed Rule regarding Dodd-Frank Section 1071 which covers small business lending data collection. The comment period closes January 6, 2022.
7. Earlier this month, the OCC published a Final Rule in the Federal Register which rescinded its own Final Rule regarding CRA that had been published in June 2020.
8. The comment period closed in February 2021 on a Proposed Rule regarding CRA that the Federal Reserve released in September 2020.
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