Monique Reyna

HMDA Reporting Requirements: Business Purpose Loans

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open-end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …

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trading graph

HMDA Reporting Requirements: Business Purpose Loans

The passing of Senate Bill 2155 adds another level of complexity to an already complex Regulation. The Bill exempts institutions that originate fewer than 500 closed‐end loans or open‐end lines of credit in each of the two preceding calendar years from reporting certain HMDA data points. This “relief” spurred the question, “What and how do …

HMDA Reporting Requirements: Business Purpose Loans Read More »

closing costs on paper

New Rule for Using Closing Disclosure When Resetting Tolerances

On April 26, 2018, the CFPB issued a final rule addressing utilization of a Closing Disclosure to reset tolerances under the TILA‐RESPA Integrated Disclosure Rule (TRID). Under the current regulation, a creditor may only use a Closing Disclosure to reset tolerances if there are fewer than four business days between the time the creditor is …

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