Compliance Update, Third Quarter 2025

2024 HMDA Data on Mortgage Lending Now Available

 
The Home Mortgage Disclosure Act (HMDA) Modified Loan Application Register (LAR) data for 2024 are now available on the Federal Financial Institutions Examination Council (FFIEC)’s HMDA Platform for approximately 4,898 HMDA filers. The published data contain loan-level information filed by financial institutions and modified to protect consumer privacy.

To increase public accessibility, the annual loan-level LAR data for each HMDA filer are available online. Previously, users could obtain LAR data only by making requests to specific institutions for their annual data. To allow for easier public access to all LAR data, the Consumer Financial Protection Bureau (CFPB)’s 2015 HMDA rule made the data for each HMDA filer available electronically on the FFIEC’s HMDA Platform. In addition to institution-specific modified LAR files, users can download one combined file that contains all institutions’ modified LAR data.

https://www.consumerfinance.gov/about-us/newsroom/2024-hmda-data-on-mortgage-lending-now-available/

CFPB Offers Regulatory Relief From Registration Requirements for Small Loan Providers

The CFPB announced that, with respect to the regulation titled Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders, 89 Fed. Reg. 56028 (July 8, 2024) (codified at 12 CFR part 1092), it will not prioritize enforcement or supervision actions with regard to entities that do not satisfy future deadlines under the regulation to submit registration information. The Bureau will instead continue to focus its enforcement and supervision activities on pressing threats to consumers. The Bureau is further considering issuing a notice of proposed rulemaking to rescind the regulation or narrow its scope.

The deadline for the registrations for entities subject to 12 CFR 1092.206(a)(2) occurred on April 14, 2025, and the deadline for registrations for entities subject to 12 CFR 1092.206(a)(3) occurred on July 14, 2025.

https://www.consumerfinance.gov/about-us/newsroom/cfpb-offers-regulatory-relief-from-registration-requirements-for-small-loan-providers/

Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule

The federal bank regulatory agencies announced, in light of pending litigation, their intent to issue a proposal to both rescind the Community Reinvestment Act (CRA) final rule issued in October 2023 and reinstate the CRA framework that existed prior to the October 2023 final rule. The agencies will continue to work together to promote a consistent regulatory approach on their implementation of the CRA.

https://fdic.gov/news/press-releases/2025/agencies-announce-intent-rescind-2023-community-reinvestment-act-final

CFPB Announcement Regarding Enforcement Actions Related to Buy Now, Pay Later Loans

 
The CFPB announced that it will not prioritize enforcement actions taken on the basis of the Truth in Lending (Regulation Z); Use of Digital User Accounts to Access Buy Now, Pay Later Loans, 89 Fed. Reg. 47,068 (May 31, 2024) (“Buy Now, Pay Later”). The Bureau will instead keep its enforcement and supervision resources focused on pressing threats to consumers, particularly servicemen and veterans. The Bureau takes this step in the interest of focusing resources on supporting hard-working American taxpayers, servicemen, veterans, and small businesses. The Bureau is further contemplating taking appropriate action to rescind Buy Now, Pay Later.

https://www.consumerfinance.gov/about-us/newsroom/cfpb-announcement-regarding-enforcement-actions-related-to-buy-now-pay-later-loans/

The First Issue 2025 of Consumer Compliance Outlook (CCO) is now available on the CCO website. This issue includes the following articles and features:

• 2024 Aggregate Supervisory Data for Institutions the Federal Reserve Supervises
• Top-Cited Federal Reserve System Compliance Violations in 2024: The Home Mortgage Disclosure Act (Regulation C)
• Community Reinvestment Act (Regulation BB) Data Collection and Reporting Violations in the Federal Reserve System
• Record Retention Reference Guide for Federal Consumer Protection Laws and Regulations
• Regulatory Calendar

https://www.consumercomplianceoutlook.org/?utm_source=link&utm_medium=email&utm_content=Issue4+2024/