We and other mortgage insurers have been subject to multiple inquiries from the Minnesota Department of Commerce  relating to our captive reinsurance and contract underwriting arrangements, and in the past, we received a subpoena from the  Office of the Inspector General of the U.S. Department of Housing and Urban Development (“HUD”), requesting information  relating to captive reinsurance. The Dodd-Frank Act amended RESPA and transferred the authority to implement and enforce  the statute from HUD to the Consumer Financial Protection Bureau (the “CFPB”). In January 2012, we and other mortgage  insurers received a request for information and documents from the CFPB relating to captive reinsurance arrangements, and in  June 2012, we and other mortgage insurers received a Civil Investigative Demand (“CID”) from the CFPB as part of its  investigation to determine whether mortgage lenders and private mortgage insurance providers engaged in acts or practices in  violation of the Dodd-Frank  Act, RESPA and the Consumer Financial Protection Act. On December 7, 2012, we filed a petition  with the CFPB to set aside or modify the CID, which has not yet been ruled upon by the CFPB.  We are cooperating with the  CFPB in its investigation and are in active discussions with the CFPB with respect to our response to the CID, including  various alternatives for resolving this investigation.  Various regulators, including the CFPB, state insurance commissioners or  state attorneys general may bring actions or proceedings regarding our compliance with RESP A or other laws applicable to our  mortgage insurance business. Although we believe that all of our captive reinsurance and contract underwriting arrangements  comply with applicable legal requirements in all material respects, we cannot be certain that we will be able to successfully  defend against alleged violations of RESP A or other laws. See “Risk Factors— Legislation and regulatory changes and  interpretations could harm our mortgage insurance business”  and “ We face risks associated with our contract underwriting  business. ” The SAFE Act requires mortgage loan originators to be licensed and/or registered with the Nationwide Mortgage  Licensing System and Registry (the “Registry”). The Registry is a database established by the Conference of State Bank  Supervisors and the American Association of Residential Mortgage Regulators.  Among other things, the database was  established to support the licensing of mortgage loan originators by each state.  As part of this licensing and registration process,  loan originators who are employees of institutions other than depository institutions or certain of their subsidiaries, in each case,  that are regulated by a Federal banking agency , must generally be licensed under the SAFE Act guidelines enacted by each state  in which they engage in loan originator activities and registered with the Registry . Otherwise, the SAFE Act generally prohibits  employees of a depository institution (including certain of their subsidiaries that, in each case, are regulated by a Federal  banking agency) from originating residential mortgage loans without first registering with the Registry and maintaining that  registration. If the SAFE Act is interpreted to apply to our contract underwriters and we are unable to achieve compliance with  the SAFE Act in all applicable states, we may be required to cease or limit our contract underwriting services in some or all  states and could be subject to fines or other penalties. Most originators of mortgage loans are required to collect and report data relating to a mortgage loan applicant’ s race,  nationality, gender, marital status and census tract to HUD or the Federal Reserve under the HMDA.  The purpose of the HMDA  is to detect possible discrimination in home lending and, through disclosure, to discourage this discrimination. Mortgage  insurers are not required pursuant to any law or regulation to report HMDA  data. However, mortgage insurers have, through the  industry trade group Mortgage Insurance Companies of  America, voluntarily agreed to report the same data on loans submitted  for insurance as is required for most mortgage lenders under HMDA. The Homeowners Protection Act of 1998 (“HPA”) imposes certain cancellation and termination requirements for  borrower-paid private mortgage insurance and requires certain disclosures to borrowers regarding their rights under the law .  The HPA also requires certain disclosures for loans covered by lender -paid private mortgage insurance. Specifically , the HPA  provides that private mortgage insurance on most loans originated on or after July 29, 1999 may be canceled at the request of  the borrower once the LTV reaches 80% of the original unpaid principal balance, provided that certain conditions are satisfied.  Private mortgage insurance must be canceled automatically once the L TV reaches 78% of the unpaid principal balance (or , if  the loan is not current on that date, on the date that the loan becomes current). The HPA establishes special rules for the termination of private mortgage insurance in connection with loans that are  “high risk.” The HPA does not define “high risk” loans, but leaves that determination to the GSEs for loans up to the GSE  conforming loan limits and to lenders for any other loan. For “high risk” loans above the GSE conforming loan limits, private  mortgage insurance must be terminated on the date that the L TV is first scheduled to reach 77% of the unpaid principal balance.  In no case, however, may private mortgage insurance be required beyond the midpoint of the amortization period of the loan if  the borrower is current on the payments required by the terms of the mortgage. 50 2.  SAFE Mortgage Licensing Act (the “SAFE Act”) 3.  Home Mortgage Disclosure Act of 1975 (“HMDA”) 4.  Mortgage Insurance Cancellation