Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Submission for OMB Review; Fair Housing Home Loan Data System Regulation
Agencies
ELI5 AI
The government wants to know what people think about a rule that helps them keep track of who is asking for home loans. They are trying to see if they can make the rule simpler and less work for banks.
Summary AI
The Office of the Comptroller of the Currency (OCC) is seeking public comments on the renewal of the "Fair Housing Home Loan Data System Regulation" information collection. This request is part of the agency's effort to reduce paperwork and respondent burden, in accordance with the Paperwork Reduction Act. The regulation requires certain national banks to collect and maintain specific data on home loans, especially if they receive over 50 home loan applications annually. The OCC is asking for feedback on whether the information collections are necessary, how to reduce the burden on respondents, and any start-up or ongoing costs associated with providing the information.
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to take this opportunity to comment on a continuing information collection as required by the Paperwork Reduction Act of 1995 (PRA). An agency may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning the renewal of the information collection titled "Fair Housing Home Loan Data System Regulation." The OCC also is giving notice that it has sent the collection to OMB for review.
Keywords AI
Sources
AnalysisAI
The document in focus originates from the Office of the Comptroller of the Currency (OCC) and is a request for public commentary regarding the renewal of an information collection titled "Fair Housing Home Loan Data System Regulation." This initiative is part of a broader effort to streamline regulatory processes and reduce the paperwork burden on financial institutions, as mandated by the Paperwork Reduction Act.
General Summary
The central thrust of the document is to solicit feedback on the necessity and efficiency of a data collection process related to fair housing home loans. National banks that handle more than 50 home loan applications annually are required to gather and maintain specific data on these applications. This data includes reasons for loan denials, which must be documented and reported in certain circumstances.
Significant Issues or Concerns
One of the significant concerns highlighted by the document involves the complexity of legal references. The frequent citation of specific sections of the Code of Federal Regulations (CFR) and laws such as the Home Mortgage Disclosure Act (HMDA) may not be easily understood by those without expertise in financial regulations.
Another notable issue is the substantial administrative burden suggested by the document. With an estimated 19,864 hours devoted to compliance across 956 respondents, the time and effort required for data collection could be perceived as onerous.
Additionally, the document does not clearly articulate strategies for reducing this burden on national banks, nor does it offer concrete solutions to streamline the process. The technical language used throughout may further alienate those unfamiliar with the banking or regulatory sectors.
Impact on the Public
Broadly, the document may have significant implications for the general public, especially those engaging with national banks for home loans. By collecting more comprehensive data on loan applications and denials, the OCC aims to enforce fair lending practices effectively, which could lead to more equitable outcomes for consumers.
However, there is a potential concern that the administrative burden imposed on banks could indirectly affect loan applicants. Increased operational costs associated with compliance might be passed on to consumers in the form of higher fees or interest rates, although this is not explicitly addressed in the document.
Impact on Specific Stakeholders
National Banks: The regulatory requirements will primarily impact national banks that must collect, maintain, and possibly report detailed information on their home loan transactions. The potential complexity and cost involved in meeting these requirements pose challenges.
Regulatory Bodies: For government entities and regulatory bodies, the comprehensive data collection serves as a tool to detect and prevent discriminatory lending practices. As such, it empowers these organizations to uphold fair housing laws more effectively.
Consumers: For potential homeowners and loan applicants, the emphasis on data transparency and accountability could prove beneficial. Greater scrutiny of loan processes can help deter biased lending, promoting fairer opportunities across different demographic segments.
In summary, while the document's intentions aim to reinforce fair lending practices, the procedural demands and legal intricacies present practical challenges that may need further clarification and simplification to ensure an equitable and efficient application in the financial industry. Stakeholders may need to carefully consider the balance between regulatory compliance and operational feasibility.
Issues
• The document contains complex legal references (e.g., references to specific CFR sections and the Home Mortgage Disclosure Act) that may not be easily understood by the general public.
• The burden estimate of 19,864 hours for the estimated 956 respondents could potentially be seen as a high administrative burden.
• There is no clear explanation of how the OCC plans to minimize the burden on respondents or any potential solutions for reducing paperwork.
• The document uses technical language and terms that might not be accessible to individuals without a strong understanding of regulatory and financial industry jargon.
• The criteria for when a national bank must maintain a Fair Housing Inquiry/Application Log seem complex and might benefit from a clearer explanation or examples.