On June 28, 2024, the Consumer Financial Protection Bureau (“CFPB”) published a blog post warning lenders to comply with provisions of the Home Mortgage Disclosure Act (“HMDA”) or be held accountable. The CFPB is particularly concerned with lenders’ failure to collect borrowers’ demographic information at the time of origination of the loans. The HMDA requires lenders to collect demographic data either through self-reporting or, where the consumer refuses to report, through input by loan officers who directly engage with the consumer. The CFPB reports that its investigations uncovered mortgage lenders and originators that:  (1) failed to implement policies targeted to capture the information required by the HMDA; or (2) encouraged misreporting of the information. In November 2023, the CFPB ordered Bank of America to pay $12 million for failing to ask applicants questions required under the HMDA and for falsely reporting that applicants did not wish to provide the requested information. In June 2024, the CFPB directed Freedom Mortgage Corporation to pay almost $4 million for submitting false information and violating a 2019 CFPB order. The CFPB also ordered Freedom Mortgage to correct its HMDA data and regularly audit the information it collects. In its blog post, the CFPB advised mortgage lenders to “carefully examine their own reporting practices and HMDA compliance systems to ensure they are monitoring for inaccurate or incomplete data.” The agency noted that large lenders tend to furnish the fewest reports, signaling that the CFPB may set it sights on large banks as it continues its efforts to enforce HMDA compliance.