On June 18, the CFPB filed a proposed stipulated final judgment and order in its lawsuit against a large mortgage lender for violating HMDA, Regulation C and the CFPA. The mortgage lender agreed to pay a civil money penalty of $3.95 million. As previously covered by InfoBytes, the CFPB filed its complaint against the Florida-based nonbank mortgage lender in October 2023 to obtain relief and penalties associated with the lender’s alleged repeated failure to comply with HMDA reporting requirements and the terms of a 2019 Consent Order. In addition to the monetary penalty, the proposed order will prohibit the mortgage lender from violating HMDA, and require the development of additional policies, and issued controls to prevent errors in recording consumer and loan data and HMDA data reporting. Under the proposal, the mortgage lender must also establish an HMDA Compliance Subcommittee that will include the CEO, COO, CRO, and CLO, and retain a third-party independent auditor to perform HMDA data transaction testing, perform a root cause analysis, and issue written reports for five years. Within 30 days of the date the order will be entered by the court, the mortgage lender must create a compliance plan outlining detailed steps, designed policies, board notifications, and specific timelines. In agreeing to the proposed stipulation, the mortgage lender neither admitted nor denied the allegations in the complaint.