The Consumer Financial Protection Bureau (“CFPB”) has issued a new 2016 list of “rural or underserved” and “rural” counties as they pertain to applying regulatory provisions. “Rural” counties are defined by the USDA Economic Research Services urban influence codes. “Underserved” counties are determined by data collected under the Home Mortgage Disclosure Act.
Smaller institutions should take note as different rules regarding qualified mortgages and other regulations apply to lending activities within these geographic areas. If your organization has relied on prior lists of rural or underserved counties, it is time to verify that each county remains on the list.
If you have questions regarding the application of mortgage origination provisions that vary in rural or underserved counties, please contact Spilman.