MBA offers recommendations on proposed HMDA rule.

Author:Tucker, Michael
Position::Commercial - Mortgage Bankers Association - Home Mortgage Disclosure Act
 
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The Mortgage Bankers Association (MBA) questioned whether a Consumer Financial Protection Bureau (CFPB) proposal to increase Home Mortgage Disclosure Act (HMDA) data reporting should apply to multifamily mortgage loans and other business-purpose loans.

In a letter to the CFPB, MBA recommended that the agency exclude multifamily mortgage loans and other loans made for business purposes from HMDA reporting requirements in light of the core purposes of HMDA and the fundamentally different nature of multifamily and commercial real estate lending from single-family residential lending.

The letter said the CFPB was established to "regulate the offering and provision of consumer financial products or services under federal consumer laws," among other things, and that among the CFPB's general powers is the enforcement of consumer financial laws for "the purpose of ensuring all consumers have access to markets for consumer financial products and services...." It recommends that the consumer-centric character of the core purpose of HMDA and the mission of the CFPB should shape the scope of HMDA reporting and that multifamily mortgage loans made for business purposes and other business loans should not be subject to HMDA reporting.

In contrast to single-family home mortgage finance, which currently relies heavily on government programs and standardized terms, "the capital sources...

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