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Volume 29 - Number 18

September 3, 2018

CFPB Clarifies HMDA Relief, Formal Rulemaking to Come Later

The CFPB late last week issued a rule to clarify partial HMDA exemptions for small financial institutions ushered in under the Dodd-Frank reform act. The Economic Growth, Regulatory Relief, and Consumer Protection Act, signed into law in May, exempts depositories – including credit unions – that originated fewer than 500 closed-end mortgages or 500 open-end lines of credit in each of the two preceding calendar years from certain expanded reporting ...

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Who "owns" the mortgage customer that’s brought to a wholesale lender through a loan broker?

The broker. It’s his/her client.
The wholesale/table funder. They’re taking the financial risk.
The broker, but only for the first year. After that, the borrower is fair game.
Hard to answer. It’s a complicated issue.

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