Home Mortgage Disclosure Act

[Marco Bario]

I was reading a bit about the new almost 800-page long CFPB Home Mortgage Disclosure Act which takes effect Jan 1, 2018. As I understand it, the document serves to amend the existing HMDA "made by section 1094 of the Dodd-Frank Wall Street Reform and Consumer Protection Act".

I'm curious if investors who purchase and restructure non-performing notes are required to abide by either the current or the new act. 

From the new Act:

"The loan-volume thresholds require an institution that originated at least 25 closed-end mortgage loans or at least 100 open-end lines of credit in each of the two preceding calendar years to report HMDA data, provided that the institution meets all of the other criteria for institutional coverage."

I'm not sure if a small independent investor like myself, even if I reached the 25-loan threshold falls within the scope. And there there is the question of wether purchasing and restructuring loans is viewed as originating.

Thanks,

Marco Bario