As we ring in the new year, it is helpful to recap what has happened in 2020 on three different fronts: HMDA, fair lending, and CRA. I count eight important developments. These are listed in no particular order below:
1. Modifications to the 2020 and 2021 HMDA Filing Instruction Guides (FIGs)
The 2020 FIG was revised three times in 2020, with the most recent revision coming in June 2020.
The 2021 FIG was updated as recently as November 2020. Changes to the 2021 FIG, relative to 2020, include the addition of a new code which allows institutions to report that an “Internal Proprietary System” was used to obtain an automated underwriting recommendation. Please consult the FIG for additional changes.
2. Modifications to the thresholds for reporting closed- and open-end transactions in HMDA.
The closed-end thresholds adjusted in July 2020. See this chart as a reference.
3. The CFPB in March 2020 allowed large HMDA reporters to indefinitely delay quarterly reporting.
4. The 2019 HMDA Snapshot data were released in June 2020.
5. The first federal redlining lawsuit targeting a non-depository mortgage company was filed by the CFPB in July 2020.
6. Paycheck Protection Program loans prompted widespread discussion around equal access to credit
See our blog on how we added new tools to assist in analysis. The funding was authorized by the March 2020 “CARES Act” and the December 2020 “Coronavirus Response and Relief Supplemental Appropriations Act, 2021” legislation.
7. The OCC in May 2020 released a Final Rule regarding Community Reinvestment Act (CRA) performance evaluations.
8. Finally, the Federal Reserve in September 2020 released an Advance Notice of Proposed Rulemaking (ANPR) regarding CRA performance evaluations.
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