Commentary Comment Letter on Proposed Rule for Home Mortgage Disclosure (Regulation C)
Ellen Seidman, Laurie Goodman, Jun Zhu
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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.
Research Areas Wealth and financial well-being Neighborhoods, cities, and metros Housing finance Housing
Tags Federal housing programs and policies Asset and debts Housing and the economy Multifamily finance Single-family finance Multifamily housing Financial products and services Inequality and mobility Opportunity and ownership Finance
Policy Centers Housing Finance Policy Center