Comment Letter on Proposed Rule for Home Mortgage Disclosure (Regulation C)

Commentary

Comment Letter on Proposed Rule for Home Mortgage Disclosure (Regulation C)

Abstract

This comment letter responds to the Consumer Financial Protection Bureau’s proposal to amend Regulation C to increase the reporting threshold under the Home Mortgage Disclosure Act. The researchers provide evidence that increasing the reporting threshold from 25 to 50 loans would materially affect the amount of information available to the marketplace, especially for rural and low and moderate-income areas and for multifamily loans. Moving the threshold to 100 would exacerbate the problem exponentially. They urge the CFPB to retain the 25 loan threshold and, in no event to increase it to more than 50.

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