The Consumer Financial Protection Bureau's warning letters about Home Mortgage Disclosure Act obligations has prompted speculation that the regulator once again has mini-correspondent lenders in its sights.

The bureau did not name the 44 mortgage lenders and brokers that it said received letters. But brokers are not required to report HMDA data, nor will they be required to under the revised set HMDA rules that take effect in 2018. So a logical interpretation is that the bureau targeted so-called mini-correspondents, a popular stepping-stone structure for mortgage brokers that want to fund loans in their own names. The mini-correspondent setup has faced regulatory scrutiny amid concerns the business model is used to evade consumer protection laws.

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