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Dreher Tomkies LLP
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2750 Huntington Center
41 South High Street
Columbus, Ohio 43215
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Effective Date of New Home Mortgage Disclosures Postponed; Use of 2000 Census Data Required

by Jean M. McCarthy*

The Federal Reserve Board has postponed the effective date from January 1, 2002 to January 1, 2004 of amendments to Regulation C that increase the amount and quality of mortgage loan information made available to federal regulators and consumer advocates. See 67 Fed. Reg. 30771‑01 (May 2, 2002).

The Federal Reserve Board adopted new home mortgage data collection regulations effective January 1, 2003. Among other changes, the amendments:

  • Expand the coverage of non-depository lenders by adding a $25 million volume test;
  • Require lenders to report the spread between APR and the yield on comparable Treasury security for originated loans with a spread tentatively set at 3% for first liens and 5% for subordinate liens;
  • Require lenders to identify “high cost” loans subject to the Home Ownership Protection Act (HOEPA);
  • Conform the categories for reporting race and ethnicity to government-wide standards, permitting multiple racial designations and eliminating the option of a generic “other” designation; and
  • Add reporting requirements for certain preapproved programs.

Separately, the Board is seeking comment on several topics:

  • The appropriate threshold for reporting of the spread between APR and yield on Treasury securities (discussed above);
  • Whether lien status (first, subordinate, unsecured) should be reported on applications and loans; and
  • Whether lenders should be required to ask an applicant’s ethnicity/race/sex in phone applications.

Comments are due April 12, 2002.

If we can help you to comply with home mortgage disclosure compliance, prepare a comment letter or address fair lending issues, or if you would like a copy of the new regulations or request for comment, please do not hesitate to call us.

* Jean M. McCarthy is an Associate with Dreher Tomkies LLP and is
the Managing Editor of the Firm’s Residential Mortgage Loan Digest.
She can be reached at jmccarthy@dltlaw.com or 614-628-1606.