January 9 – Read the newsletter below for the latest Mortgage Banking and Consumer Finance industry news, written by Ballard Spahr attorneys. In this issue, we cover recent happenings at the CFPB, the NFIP extension, Rocket Mortgage’s filed complaint against HUD, and much more.
- This Week’s Podcast Episode: Alan Kaplinsky’s ‘Fireside Chat’ With Former CFPB Leader David Silberman - His Experience During the Prior Transition From the Obama Administration to Trump 1.0
- Last Week’s Podcast Episode: Banks Aren’t Over-Regulated, They Are Over-Supervised
- Last Week’s Podcast Episode: Navigating the New CFPB Open Banking Rule
- The CFPB Issues Final Rule on PACE Transactions
- Rocket Mortgage Turns the Table on HUD
- DOJ and the CFPB Remind Institutions of Rate Protections for Servicemembers
- The CFPB Issues Fall Regulatory Agenda
- NFIP Extended to March 2025
- The CFPB Adjusts HPML Asset Exemption Threshold
- The CFPB Adjusts HMDA Asset Exemption Threshold
- Looking Ahead
Today’s podcast episode is a repurposing of part one of our December 16 highly-attended and praised webinar consisting of Alan Kaplinsky’s exclusive interview of David Silberman, who held several senior positions at the CFPB for almost 10 years under both Democratic and Republican administrations. Part two of our December 16 webinar, featuring Ballard Spahr Partners John Culhane and Joseph Schuster, is to be released on January 9, 2025. They focus their attention on the impact of the election on the CFPB’s regulations (final and proposed). Our December 16 webinar is the first part of our three-part intensive look at this transitional period for the CFPB. The goal of our three-part series is to help us predict what is in store for the CFPB during the next four years.
As a former senior leader at the CFPB during the only other transition of the CFPB from a Democratic to a Republican administration led by former President Trump, Mr. Silberman has special insight about what is likely to happen to the CFPB during President-elect Trump 2.0.
While nobody yet knows who President-elect Trump will nominate as the next CFPB director, Mr. Silberman makes the point that, of potentially greater importance, at least initially, is who President-elect Trump selects as the acting director. If what happened in President Trump 1.0 is any indication, the acting director may end up serving for a lengthy period of time just like Mick Mulvaney served as acting director for a lengthy period of time before Kathy Kraninger was nominated by former President Trump, confirmed by the Senate, and sworn-in as director. Under the Vacancy Reform Act, the acting director must be either a current senior officer of the CFPB or someone who has already been confirmed by the Senate for a different position.
Among other things, Mr. Silberman addressed the following topics during his interview:
- What were some of the first steps that Mr. Mulvaney took when he became acting director and will they be replicated by a new acting director?
- How will a new acting director deal with the many lawsuits brought by trade groups challenging CFPB final rules issued by Director Chopra? Will there be a distinction made between final rules in which district courts have ruled on motions for preliminary injunction and those where courts have not so ruled? Will there be distinctions made between final rules where courts have granted or denied injunctive relief? Finally, will there be distinctions made between final rules mandated by Dodd-Frank and so-called discretionary rules?
- Which final rules are still subject to being overridden by the Congressional Review Act and what are the odds of that happening with respect to any of such rules?
- How will the new acting director deal with proposed rules as of January 20?
- How will the new acting director deal with CFPB enforcement investigations and lawsuits initiated by Chopra, including those which arguably “push the envelope” with respect to the CFPB’s jurisdiction?
- Will the new acting director agree with many industry pundits that the CFPB has been unlawfully funded by the Federal Reserve Board since September, 2022 in light of the language in the Dodd-Frank Act which permits funding of the CFPB only out of “combined earnings of the Federal Reserve Banks” and the fact that there have been no such combined earnings since September 2022 and the likelihood that no such combined earnings are anticipated in the near future. Does this impact actions taken by the CFPB since September 2022?
- What role, if any, will the White House play in directing or influencing CFPB policy? What impact, if any, might the Department of Government Efficiency (DOGE) have on the CFPB?
- Do you expect the new acting director to initiate any rulemakings other than those required by Dodd-Frank?
- Will the new acting director be more supportive of innovation than Chopra and, if so, how will that be reflected?
Senior Counsel and former chair for 25 years of the Consumer Financial Services Group, Alan Kaplinsky, hosts the discussion.
A link to the podcast appears here.
For more information about our January 6 webinar featuring Kathy Kraninger (former Director of the CFPB during President Trump 1.0), click here.
For more information about our January 17 webinar featuring Matthew G. Platkin (New Jersey Attorney General who will discuss the role of state AGs in a shifting the CFPB landscape), click here.
Consumer Financial Services Group
Last Week’s Podcast Episode: Banks Aren’t Over-Regulated, They Are Over-Supervised
In last week's podcast episode, we are joined by Raj Date, who has served in a variety of roles at the Consumer Financial Protection Bureau, including as the acting head of the agency and as it’s first-ever Deputy Director. He recently wrote a thought-provoking article in a new online publication, Open Banker, entitled “Banks Aren’t Over-Regulated, They Are Over-Supervised.”
Senior Counsel in Ballard Spahr’s Consumer Financial Services Group, Alan Kaplinsky, leads the discussion, and is joined by Joseph Schuster, a partner in the Group.
By way of background, Mr. Date described how bankers have almost uniformly complained to him that banks are over-regulated. Mr. Date responds to these complaints in his article as follows:
At the time, in the still-smoldering ruins of the financial crisis, this struck me as bizarre. Banks are the beneficiaries of an array of government privileges: subsidized leverage (through insured deposits), liquidity (through the discount window and the home loan banks), exclusive access to payment rails (both through the central bank and bank-only private networks), and even choice of law (through federal preemption). Given all that, safeguards on capital, liquidity, credit exposure, market and interest rate exposure, cybersecurity, and consumer protection seemed like a fair trade to me.
More than a decade later, I realize that those bank CEOs were not exactly wrong, they were imprecise: Banks are not over-regulated, but they are—quite dramatically—over-supervised.
Mr. Date makes the following points in support of his thesis that the banking industry is over-supervised:
- Bank examination tries to cover too many areas and, as a result, sometimes fails to see the forest through the trees.
- Bank examination obsessively focuses on process rather than substance. That focus is evidenced by the supervisors’ requirements that the banks document everything.
- It takes far too long for banks to receive examination reports after exams are completed, sometimes years later. The final exam reports are often anachronistic.
- Bank examinations often stultify bank innovation because supervisors’ examinations are often critical of banks offering new products and services and this results in bank management being reluctant to innovate out of fear that they will be downgraded.
- Examiners’ focus on process rather than risk itself has resulted in a bank management brain drain.
Mr. Date then explains how the examination process should be changed. Mr. Date first calls for immediate changes even though the banking industry is largely thriving.
Mr. Date suggests the following approach in his article and during the podcast:
The regulatory agencies are, probably justifiably, proud of their long histories of public service. But that pride breeds cultures that are strikingly conservative and resistant to change. As importantly, unlike private sector firms, they do not have the crucible of a profit imperative to burn away unproductive practices and orthodoxies. And it shows. It is not as though bank examiners cannot articulate the most important issues facing their regulated charges; it is just that they often just have no reason to stop working on things other than the most important issues.
The only solution is strong top-down leadership that imposes ambitious goals. Without stretch goals that will feel strikingly out of reach at the outset, real change will not be possible. If it were me, I would set out, in a pilot with a handful of mid-sized banks, to structure a supervisory exam strategy that costs 75 percent less (in combined bank and agency costs) and is 75 percent faster from first-day letter to final report than today’s norms.[9] I would embrace pilot uses of new technology tools in pursuit of those goals. And then I would iterate on those initial (almost certainly unsuccessful) results.
This will be difficult, and even painful. But I very much believe it will be worth it.
While acknowledging the issues with over-supervision, Joseph directs significant attention to the problem of over-regulation. He argues that modern regulatory practices have become more complex, restrictive, and less clear, creating barriers to innovation and access to credit. Joseph highlights how over-regulation stifles the development and availability of consumer finance products.
Joseph explains how products like “Buy Now, Pay Later” (BNPL) face regulatory hurdles despite addressing consumer needs effectively. Joseph also discusses the potential negative impact of proposed changes to late fee regulations, warning that such measures could limit access to credit and push consumers toward higher-cost alternatives. Joseph criticizes the heavy-handed approach taken by regulators, such as the CFPB’s issuance of circulars, which adds further uncertainty and complexity for institutions attempting to innovate in this space.
Joseph advocates for a return to a more structured and transparent regulatory framework. He suggests that agencies recommit to the principles of the Administrative Procedures Act (APA), emphasizing the importance of notice-and-comment rulemaking. Drawing parallels to the Federal Reserve Board’s process during the implementation of the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act, Joseph argues that meaningful engagement with the industry could lead to clearer regulations that balance consumer protection with innovation and operational feasibility.
Joseph endorses Raj Date’s call for clear and focused priorities in the supervisory process, and emphasizes that both banks and examiners benefit from a more straightforward understanding of the rules. Joseph concludes by warning against the trend of “regulation through enforcement,” which undermines transparency and predictability, ultimately harming consumers and financial institutions alike.
To listen to this episode, click here.
Consumer Financial Services Group
Last Week’s Podcast Episode: Navigating the New CFPB Open Banking Rule
In last week’s podcast episode, we were joined by Founder of Fintech Takes, Alex Johnson, and Senior Vice President, Senior Associate General Counsel, and Co-Head of Regulatory Affairs at Bank Policy Institute, Paige Paridon, to take a deep dive into the new Consumer Financial Protection Bureau Open Banking Rule.
The CFPB has issued a groundbreaking final rule implementing Section 1033 of the Dodd-Frank Act, significantly expanding consumer access to their financial data. This new Open Banking Rule will have far-reaching implications for financial institutions, Fintech companies, and consumers alike. In this episode, we’ll explore the key aspects of this landmark regulation, such as:
- The scope, rule requirements, and compliance deadlines
- Complexities of implementing new interfaces and data security measures
- Potential pitfalls and best practices to mitigate risks, including a lawsuit challenging the legality of the rule
- How the rule can foster innovation and enhanced consumer experiences
- The impact of the presidential election and presumed appointment of new Acting Director of CFPB
Former Practice Leader and current Senior Counsel in Ballard Spahr’s Consumer Financial Services Group, Alan Kaplinsky, moderates this episode, and is joined by Gregory Szewczyk and Hilary Lane, partners in Ballard’s Privacy and Data Security Group.
To listen to this episode, click here.
Consumer Financial Services Group
The CFPB Issues Final Rule on PACE Transactions
As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act), enacted in 2018, directs the CFPB to prescribe regulations that apply Truth in Lending Act (TILA) ability-to-repay (ATR) requirements to Property Assessed Clean Energy (PACE) transactions, and apply the TILA civil liability provisions to violations of the requirements. The CFPB recently issued a final rule that more broadly applies TILA requirements, with certain revisions and exemptions, to PACE transactions. The final rule is effective March 1, 2026.
For purposes of the final rule, a PACE transaction is defined as “financing to cover the costs of home improvements that results in a tax assessment on the real property of the consumer.” The CFPB explains in the preamble to the final rule that:
“PACE financing enables property owners to finance upgrades to real property through an assessment on their real property. Eligible upgrade types vary by locality but often include upgrades to promote energy efficiency or to help prepare for natural disasters. The voluntary financing agreements are made between the consumer and the consumer’s local government or a government entity operating with the authority of several local governments, and they leverage the property tax system for administration of payments. PACE financing is repaid through the property tax system alongside the consumer’s other property tax payment obligations. PACE loans are typically collected through the same process as real property taxes. Local governments typically fund PACE loans through bond issuance. PACE assessments are sometimes collateralized and sold as securitized obligations.” (Footnotes omitted.)
The CFPB also notes that PACE financings are secured by a lien on the consumer’s real property, and that the lien typically has priority under state law similar to that of other real property tax liens, which are superior to other mortgage liens on the property, including those that predated the PACE lien.
Currently the Regulation Z Commentary excludes tax liens and tax assessments from being considered credit. To cover PACE transactions, the final rule amends the Commentary to narrow the exclusion to involuntary tax liens and involuntary tax assessments. Based on this revision, PACE transactions, which result in voluntary tax assessments, will now be considered credit for TILA purposes. As a result, PACE transactions will be subject to TILA/Regulation Z provisions applicable to mortgage loans, with various revisions and exemptions made in the final rule. Among other TILA requirements, based on the final rule PACE transactions will be subject to:
- The general ability to repayment requirements, with certain revisions, and will not be eligible for qualified mortgage status.
- Disclosure requirements, including the TILA/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) rule disclosure and waiting period requirements. The rule includes model versions of the Loan Estimate and Closing Disclosure that are modified to account for the unique nature of PACE transactions. However, the transactions are exempted from the periodic statement disclosure requirements.
- Higher-priced mortgage loan (HPML) requirements, although they are exempt from the HPML escrow account requirement. Transactions above a certain threshold will be subject to the HPML appraisal requirements. The threshold for 2024 is $32,400 and for 2025 is $33,500. As noted above, the rule will become effective March 1, 2026. In late 2025 the threshold will be inflation-adjusted for 2026. In the preamble to the final rule the CFPB states it “understands that PACE companies typically do not obtain written appraisals for properties securing PACE transactions, relying instead on automated valuation models.” Based on a study of PACE transactions that the CFPB conducted in connection with the development of the final rule, the CFPB determined that about a quarter of PACE transactions exceed the threshold and, thus, would require an appraisal.
- High-cost mortgage loan requirements. Based on a study of PACE transactions that the CFPB conducted in connection with the development of the final rule, it found that the transactions generally would not trigger the high-cost mortgage loan requirements based on the annual percentage rate or prepayment penalty triggers, but about 35 percent of the transactions would trigger the requirements based on the points and fees trigger. The CFPB acknowledges in the preamble to the final rule that there are high-cost mortgage loan requirements that “may be difficult for PACE companies to comply with. This could lead to PACE companies declining to make PACE transactions that would be high-cost mortgages.”
- Loan originator qualification and compensation requirements. This may result in home improvement contractors who solicit PACE transactions having to comply with the requirements.
- Right of rescission requirements. PACE transactions already can be subject to right to cancel requirements under state laws authorizing the transactions or industry practice.
The final rule could face obstacles. The CFPB will submit the rule to Congress under the Congressional Review Act, and Congress could decide to strike down the rule, even though it directed the CFPB in the Growth Act to extend the ability to repay requirements and civil liability provisions to PACE transactions. Potentially, Congress may believe that the CFPB went too far in extending all of TILA’s provisions, with revisions and exemptions, to the transactions. Congress also could amend or repeal the authorizing provision in the Growth Act. The final rule also may face challenges from private parties or state government entities. PACE industry members commenting on the proposed rule believed subjecting PACE transactions to TILA requirements in general was beyond the CFPB’s statutory authority, with some noting in particular that the Growth Act only refers to subjecting the transactions to the ability to repay requirements and civil liability provisions.
Rocket Mortgage Turns the Table on HUD
As previously reported, this summer the U.S. Department of Housing and Urban Development (HUD) filed a housing discrimination charge under the Fair Housing Act against an appraisal company, individual appraiser, appraisal management company and lender based on an asserted biased appraisal and denial of a mortgage refinance loan application based on the appraisal. The lender, Rocket Mortgage, has now filed a complaint against HUD in the U.S. District Court for the District of Colorado focusing on an issue of concern for mortgage lenders—how to address the recent government focus on viewing lenders as being responsible for policing appraisers regarding appraisal bias and yet comply with pre-existing government appraiser independence requirements that limit the extent to which a lender can interact with appraisers.
As Rocket Mortgage observes in its complaint, the competing factors put “Rocket Mortgage between the proverbial “rock and a hard place.” If it takes action with an appraiser regarding an allegedly discriminatory appraisal, then it faces the prospect of a government enforcement action or private lawsuit alleging violations of statutory appraiser independence requirements. But if it complies with those independence requirements by not taking action to “directly or indirectly” attempt to influence the “independent judgment” of a third-party appraiser, then it faces the prospect of government enforcement actions and private lawsuits for alleged violations of the FHA. This reality of the government’s inconsistent and conflicting approach requires judicial intervention.”
Focusing on the lack of guidance from HUD, or other government agencies, regarding the competing factors, Rocket Mortgage also states that “[w]hen confronted with the problem of irreconcilably competing federal obligations, HUD has simply ducked the problem, instead expecting mortgage lenders to solve for themselves the paradox of intervening to “correct” appraisers’ actions while following appraiser independence rules. Worse still, it has avoided public scrutiny over that tension by failing to provide notice of, and an opportunity to comment on, its new policy of seeking to hold lenders responsible for the actions of independent appraisers under the FHA.”
Rocket Mortgage requests a declaratory judgment that (1) it is not liable as a lender under the Fair Housing Act for an appraisal by an independent, third-party appraiser, and (2) the Truth in Lending Act’s appraiser independence requirements precludes any requirement for a lender to “instruct” or “induce” an appraiser to address or correct a valuation for issues implicating the Fair Housing Act. Rocket Mortgage also asserts that HUD’s new policy seeking to hold mortgage lenders responsible for alleged bias or discrimination by an independent, third-party appraiser could not be implemented without HUD following the notice and comment requirements under the Administrative Procedure Act. Rocket Mortgage requests that the court issue an order vacating HUD’s policy of holding mortgage lenders responsible for failing to correct or remediate perceived or alleged appraiser bias or discrimination in an appraisal.
Richard J. Andreano, Jr. and John L. Culhane, Jr.
DOJ and the CFPB Remind Institutions of Rate Protections for Servicemembers
The Servicemember Civil Relief Act (SCRA) limits the amount of interest that may be charged on certain financial obligations that were incurred before military service began to no more than six percent per year, including most fees and charges, the CFPB and the Justice Department reminded financial institutions in a recent letter.
The six percent SCRA benefit applies to all types of financial obligations and liabilities, including credit cards; automobile, ATV, boat, and other vehicle loans; student loans; home equity loans; and mortgage loans.
For mortgages, interest is capped at 6 percent during the entire period of military service and for one year after the period of military service. For all other obligations, interest is capped at six percent only for the duration of the period of military service.
The letter, signed by CFPB Director Rohit Chopra and Kristen Clarke, the DOJ’s assistant secretary for civil rights, also reminds financial institutions that:
- The SCRA provides interest rate protections to servicemember spouses who are jointly liable with the servicemember for the loan or obligation, which can be the case when the spouse is a cosigner on the loan.
- For most servicemembers, SCRA protections begin on the date they enter active-duty military service. For reservists, protections begin upon the receipt of certain military orders, which in some cases, may occur months before the entry into active duty.
- Members of the National Guard are covered by the SCRA when serving under Title 10 orders for federal active duty, including training orders. Under 32 U.S.C. § 502(f), members of the National Guard are also covered by the SCRA when they are on orders to respond to a national emergency, as declared by the President or Secretary of Defense, for more than 30 days.
- Most SCRA benefits end when a servicemember leaves military service, although there are two limited situations in which a veteran is eligible for SCRA protections. First, a veteran continues to be able to request the interest rate benefit up to 180 days after the end of military service. Second, for mortgages, the six percent interest rate benefit continues one year after military service ends.
- Creditors can verify a borrower’s military status using the Defense Manpower Data Center (DMDC) database.
The letter closes by encouraging creditors to go beyond the letter of the law by providing rate relief to eligible borrowers after checking the DMDC database, rather than waiting for borrowers to request relief, and by providing rate relief on all of a borrower’s eligible loans even if the borrower only seeks relief on one particular loan.
John L. Culhane, Jr. and Joseph Schuster
The CFPB Issues Fall Regulatory Agenda
The CFPB has issued a list of regulatory matters under consideration between now and October 2025, although many of the regulatory initiatives face an uncertain future once the Trump Administration takes office.
The CFPB has an ambitious agenda.
For instance, this month, the bureau said that it expects to issue a final rule governing the use of medical debts in credit reports. It also expects this month to issue a final rule governing the charging of nonsufficient fund fees for consumers who engage in transactions that are instantaneously declined based on the transactions exceeding their account balances.
Not all the rules the bureau listed will be issued soon. For instance, the bureau said it expects to issue in July, 2025, a final rule intended to simplify and streamline mortgage servicing rules. The mortgage industry thought the bureau might issue the rule by January 20, when President-elect Donald Trump takes office.
As noted, all of the rules listed in the Regulatory Agenda face an uncertain future. Bureau Director Rohit Chopra, a proponent of strict regulations, is likely to lose his job when the new administration takes office, creating uncertainty about all CFPB regulatory activity. During his first term in office, Trump Administration officials made it clear that they opposed the strict regulatory regime of Democratic administrations. However, reversing course on final rules that have been adopted is not without its obstacles.
The CFPB has been particularly busy during the past few weeks. For instance, the CFPB has issued its long-awaited and controversial final overdraft regulation. And the bureau has released its final rule that applies certain existing residential mortgage protections to Property Assessed Clean Energy (PACE) loans. In addition, it has issued proposed rules and taken enforcement actions.
The CFPB has engaged in those activities even though the Republican leaders of the House and Senate committees overseeing the bureau asked Chopra to pause rulemaking during the remainder of the transition period.
Consumer Financial Services Group
The continuing resolution passed by Congress late last week provides for an extension of the National Flood Insurance Program (NFIP) until March 14, 2025. While the mortgage industry has for years advocated for a long-term authorization of the NFIP, Congress has not done so and has provided for temporary authorizations of the NFIP in short-term and end-of-year appropriations measures.
Consumer Financial Services Group
The CFPB Adjusts HPML Asset Exemption Threshold
The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML).
Regulation Z, which implements the TILA, generally requires creditors to maintain an escrow account for the payment of taxes and insurance on a first lien HPML. There are two creditor-based exemptions to the escrow account requirement. The original exemption is for creditors with assets below a certain threshold that also meet additional criteria, which include (among other criteria) extending a first lien loan subject to the Regulation Z ability to repay rule (a “covered loan”) in a rural or underserved area and having a covered loan volume, with affiliates, at or below a certain level. The asset threshold is subject to annual adjustment based on inflation. For purposes of the asset threshold, a creditor’s assets include the assets of any affiliate that regularly extends covered loans. The asset threshold for 2024 is $2.640 billion. The final rule increases the asset threshold for 2025 to $2.717 billion. As a result, if a creditor’s assets, together with the assets of its applicable affiliates, are less than $2.717 billion on December 31, 2024, and the creditor satisfies the additional criteria, the creditor will be exempt from the escrow account requirement for HPMLs in 2025. Additionally, based on a grace period in the HPML rule, such a creditor will also be exempt from such requirement for purposes of any loan consummated in 2026 if the application was received before April 1, 2026.
The asset size threshold for purposes of the original exemption from the HPML escrow account requirement also is one of the criteria that determines whether a creditor qualifies under the ability to repay rule to make loans based on the small creditor portfolio, and small creditor balloon payment, qualified mortgage loan provisions. As a result, for 2025 the $2.717 billion threshold will apply for purposes of determining if a creditor is a small creditor under such provisions.
The Economic Growth, Regulatory Relief, and Consumer Protection Act, adopted in 2018, required the CFPB to add an additional exemption from the HPML escrow account requirements for insured depository institutions and insured credit unions. The additional exemption applies to insured depository institutions and insured credit unions with assets at or below a certain threshold that also meet additional criteria, which include (among other criteria) extending a covered loan in a rural or underserved area and having a covered loan volume, with affiliates, at or below a certain level, that is lower than the level under the original exemption. The asset threshold for 2024 is $11.835 billion. The final rule increases the asset threshold for 2025 to $12.179 billion. As a result, if an insured depository institution’s, or insured credit union’s, assets are $12.179 billion or less on December 31, 2024, and the entity satisfies the additional criteria, the entity will be exempt from the escrow account requirement for HPMLs in 2025. Additionally, based on a grace period in the HPML rule, such an insured depository institution or insured credit union will also be exempt from such requirement for purposes of any loan consummated in 2026 if the application was received before April 1, 2026.
The CFPB Adjusts HMDA Asset Exemption Threshold
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA).
Banks, savings associations, and credit unions are not subject to the mortgage loan data collection and reporting requirements under HMDA for a calendar year if their assets as of December 31 of the prior calendar year did not exceed an asset threshold. The asset threshold is subject to annual adjustment based on inflation. The asset threshold for calendar year 2024 HMDA data collection and reporting is $56 million. The final rule increases the asset threshold for calendar year 2025 HMDA data collection and reporting to $58 million. As a result, banks, savings associations, and credit unions with assets of $58 million or less as of December 31, 2024, are exempt from collecting and reporting HMDA data for 2025 activity.
Consumer Financial Services Group
The Impact of the Election on the CFPB - Part 3
A Ballard Spahr Webinar | January 17, 2025, 1:00 PM – 2:30 PM ET
Speakers: Alan S. Kaplinsky, John L. Culhane, Jr., Mike Kilgarriff, Adrian R. King, Jr., and Jenny N. Perkins
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