HMDA, TILA/RESPA, and Fair Lending Violations in Origination
Definition
Savings institutions engaged in mortgage origination have been penalized for failing Home Mortgage Disclosure Act (HMDA) reporting requirements, improper TILA/RESPA (TRID) disclosures, and discriminatory underwriting and pricing patterns. These violations generate direct civil money penalties, mandated customer remediation, and expensive remediation programs to fix origination controls.
Key Findings
- Financial Impact: Individual enforcement actions and settlements commonly range from several million to tens of millions of dollars, with additional multi‑million‑dollar internal remediation and monitoring costs over several years
- Frequency: Daily
- Root Cause: Incomplete or inaccurate capture of data fields in loan origination systems, inconsistent application of underwriting guidelines across branches, and inadequate compliance monitoring of pricing and denials by prohibited bases (race, gender, etc.).
Why This Matters
This pain point represents a significant opportunity for B2B solutions targeting Savings Institutions.
Affected Stakeholders
Compliance and fair lending officers, Mortgage underwriters, Loan officers, Data and reporting teams, Internal audit
Deep Analysis (Premium)
Financial Impact
$100,000-$2,000,000 per pattern of escrow mishandling; regulatory penalties for improper escrow administration • $50,000-$500,000 per disclosure error (CFPB enforcement + borrower remediation); aggregate multi-million if scaled across portfolio
Current Workarounds
CSR forwards to voicemail, manually emails Loan Estimate PDFs without validation, uses generic email templates, relies on memory of disclosure rules • Deposit specialist creates account in core banking system manually; handwritten checklist of items to track; Excel spreadsheet of escrow balances; email coordination with loan team about fee disbursements
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Methodology & Sources
Data collected via OSINT from regulatory filings, industry audits, and verified case studies.
Evidence Sources:
- https://www.consumerfinance.gov/compliance/supervision-examinations/mortgage-origination-examination-procedures/
- https://www.fdic.gov/resources/supervision-and-examinations/consumer-compliance-examination-manual/documents/5/v-9-1.pdf
- https://www.consumerfinance.gov/enforcement/actions/american-express-centurion-bank-fair-lending-mortgages/
Related Business Risks
Improper Loan Origination Fees and Unrefunded Charges
Excess Manual Processing and Rework in Origination and Underwriting
Defective Originations Leading to Repurchases and Loss Mitigation Costs
Extended Cycle Times from Application to Closing Slow Fee and Interest Recognition
Bottlenecks in Underwriting and Conditions Clearing Limit Origination Capacity
Income, Occupancy, and Appraisal Fraud in Mortgage Applications
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