How fun! Thanks for the notice.

Oh boy....only 573 pages!

There is a lot of informative detail in there.

I was going to click on the link until I saw that.

The MISMO thing sounds very unfriendly to community banks.

Just from reading the summary I'm inclined to believe HMDA saved the American city, eliminated discrimination, and stopped subprime lending. I'll go ahead and assume these new changes will save America and possibly cure cancer.

!!!

Along with expanded reporting, there is valuable help in clear definitions on common problems, questions posed re commercial loans, limit changes that get very small reporters off the hook while bringing in non bank reporters into reporting ( there was a disconnect). We should all read it and send in our professional well thought out comments.

I just tried to comment and............i'm lost. I clicked on the link mentioned at the beginning of the rule, but once there i couldn't find the actual place to comment on this particular rule. I typed in the Docket No. CFPB-2014-0019 or RIN
3170-AA10 and got nothing. (I'm sure i just don't know what i'm doing.)

I read the summary just so I have a general idea of what they are proposing. Sounds about what I expected (that's neither a compliment or a complaint). Since we've got some time before comments are due, I want to download whole thing and read through it at a slower pace.

Can somebody give me more info. on the MISMO thing? We're strictly a portfolio lender, so it would be nice to know what they're talking about there.

(I mean...i get the general gist of what they're talking about, but some details please on what exactly MISMO consists of.)

MISMO

http://www.mismo.org/default.htm

If I'm reading this correctly, they did not change the requirement that an institution have a branch or home office in an MSA before being required to report. In other words, we did not lose 1003.2(g)(ii).

Please someone confirm I'm not missing something crucial, because at one time there was talk...

"Under the proposal, depository and nondepository institutions that meet all other criteria for a financial institution under Regulation C would be required to report HMDA data if they
originated 25 covered loans..."

I would say the MSA restriction is still in place.

They had said previously they were likely to leave that.

I don't think we're able to comment on it yet. If you type HMDA into the keyword search after clicking the link, you get nothing but old HMDA stuff where the comment period has been closed for a long time.

For those of you that have been subject to HMDA in the past, is the creation of a Universal Loan Identifier something completely new? We were not a HMDA reporter, but will be starting next year, as we opened a branch in an MSA this year.

Yes it is new for HMDA.

I have been working my way through this. There are good definitional changes (boats, RVs, park model homes and old mobile homes, as well as floating homes used as residences would not be reportable), unsecured home improvement loans would not be reportable.

A big change on which they are specifically asking for input is required reporting of HELOCs, as well as all commercial lines of credit secured by a residence. There is discussion on why the focus on business loans having to do with small businesses borrowing against their homes when credit was tight and then losing the homes to foreclosure when the economy tanked, adding to the woes of cities and towns.

Am I reading this right? We will have to report ANY loan secured by a dwelling even if it's not for a purchase/improvement/refi? I find it hard to believe anyone will be able to stay under the 25 loan threshold if that's true. Do others read this the same way?

Yes, that was my take but I plan to re-read that.

Thanks Kathleen. I went down to the definitions and see this:

(e) Covered loan means a transaction that is, as applicable, a closed-end mortgage loan
under paragraph (d) of this section, an open-end line of credit under paragraph (o) of this section,
or a reverse mortgage under paragraph (q) of this section.

(d) Closed-end mortgage loan means a debt obligation secured by a lien on a dwelling
that is not an open-end line of credit under paragraph (o) of this section, a reverse mortgage
under paragraph (q) of this section, or excluded from this part pursuant to § 1003.3(c).

and

(o) Open-end line of credit means a transaction that:
(1) Is an open-end credit plan as defined in § 1026.2(a)(20) of Regulation Z, but without
regard to whether the credit is for personal, family, or household purposes, without regard to
whether the person to whom credit is extended is a consumer, and without regard to whether the
person extending credit is a creditor, as those terms are defined under Regulation Z, 12 CFR part
1026;
(2) Is secured by a lien on a dwelling, as defined under paragraph (f) of this section;
(3) Is not a reverse mortgage under paragraph (q) of this section; and
(4) Is not excluded from this part pursuant to § 1003.3(c).


I think we are reading it right. Yikes.

I'm glad the unsecured home improvement loan will be removed because of the unclear instructions in 'HMDA Getting it Right' about whether or not the loan was classified on the books as a HIL.