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Comment on Home Mortgage Disclosure Act Proposed Rulemaking
(2014)
  • David J Reiss, Brooklyn Law School
Abstract

The Consumer Financial Protection Bureau's Home Mortgage Disclosure Act proposed rulemaking (proposed Aug. 29, 2014) is a reasonable one. It increases the amount of information that is to be collected about important consumer products, such as reverse mortgages. It also increases the amount of important information it collects about all mortgages. At the same time, it releases lenders from having to determine borrowers’ intentions about how they will use their loan proceeds, something that can be hard to do and to document well. Finally, while the proposed rule raises some privacy concerns, the CFPB can address them.

Keywords
  • HMDA,
  • Home Mortgage Disclosure Act,
  • CFPB,
  • Consumer Financial Protection Bureau,
  • proposed rule,
  • privacy,
  • reverse mortgage,
  • Regulation C,
  • Dodd Frank,
  • mortgage market,
  • HMDA data,
  • depository,
  • nondepository,
  • covered loans,
  • unsecured home improvement loan,
  • home equity lines of credit,
  • HELOC,
  • closed-end loan,
  • open-end lines of credit,
  • reportable data requirements,
  • MISMO,
  • Mortgage Industry Standards Maintenance Organization,
  • residential mortgages,
  • DTI,
  • debt to income,
  • age,
  • cerdit score,
  • reasons for denial,
  • loan term,
  • interest rate,
  • introductory rate period,
  • non-amortizing features,
  • universal loan identifer,
  • loan originator identifier,
  • legal entity identifier,
  • disclosure,
  • reporting
Publication Date
October 29, 2014
Citation Information
David J Reiss. "Comment on Home Mortgage Disclosure Act Proposed Rulemaking" (2014)
Available at: http://works.bepress.com/david_reiss/76/