HMDA Rewrite

The CFPB has followed a study earlier this year finding significant mortgage product and price discrepancies based on race or ethnicity with a request for input (RFI) on the HMDA data on which the study was based.  This is a preliminary effort with no immediate regulatory or supervisory consequences, but it likely presages a significant HMDA-regulatory rewrite in no later than 2023 to provide still more firepower for ongoing CFPB, Department of Justice, and bank-regulatory actions against credit discrimination and redlining.