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#1946482 - 07/28/14 05:02 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
Kathleen O. Blanchard
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10K Club
Joined: Jul 2003
Posts: 17,400
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I wouldn't be surprised if that pushed out a year from those dates to allow for the extensive programming changes needed. Agreed, especially in light of the burden the cost of implementation for the 8/1/15 changes for the integrated disclosures is going to put on banks.
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#1946491 - 07/28/14 05:12 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
Kathleen O. Blanchard
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Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
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Here are the proposed fields. There is a lot of explanatory data that is key to when and what to report.
§ 1003.4 Compilation of reportable data.
(1) A universal loan identifier
(2) Insured Under National Housing Act
(3) Loan Type
(4) Preapproval
(5) Construction Method
(6) Principal Residence
(7) Amount
(8) There is no 8
(9) Location including address and geocoding
(10) Ethnicity Rate Sex and Age and Gross Annual Income
(11) Purchaser Type
(12) Rate Spread
(13) HOEPA
(14) Lien Priority
(15) Credit Score
(16) Denial Reasons
(17) Points and Fees
(18) Itemized Amounts Paid At or Before Closing
(19) Points to Reduce Rate
(20) Interest Rate if no points
(21) Interest Rate
(22) Prepayment Penalty Term in Months
(23) Debt to Income Ratio
(24) Loan to Value
(25) Term in Months to Maturity
(26) Months to First Interest Rate Change
(27) Negative Terms (Balloon, Interest Only, Negative Amortization)
(28) Property Value
(29) Manufactured Home – Real or Personal Property
(30) Manufactured Home – Land Owned or Leased
(31) Number of Dwelling Units
(32) Number of Affordable Housing Units if Multifamily
(33) Channel
(34) MLO NMLSR ID
(35) AUS System Name
(36) Reverse Mortgage Identifier
(37) Open End Line of Credit/HELOC identifier
(38) ATR and QM Identifier
(39) Amount of draw at account opening for HELOC and open end Reverse Mortgage
If there is an 8 how can there be "no 8"? I'm confused
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#1946537 - 07/28/14 06:51 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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#8 must be for the flood zone, because it looks like that's the only thing missing from just making this the full loan record.
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You call it ADD. I call it multi-tasking.
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#1946559 - 07/28/14 07:14 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Member
Joined: Jul 2008
Posts: 51
Midwest
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My guess is #8 is "type of action taken, and the date" per the current version of 1003.4.
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#1946641 - 07/28/14 09:36 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
Kathleen O. Blanchard
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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Proposed instruction 4(a)(34)-2 in appendix A provides that, in the event that the mortgage loan originator is not required to obtain and has not been assigned an NMLSR ID, a financial institution must enter “NA” for not applicable. Excellent. Thanks!
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1946657 - 07/28/14 11:37 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Diamond Poster
Joined: Jul 2007
Posts: 1,016
Pac NW
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Still reading, but....
Lower the threshold for reporting to 25 covered transactions.
-My response "Awesome! We won't have to report"
Covered transactions now include business loans secured by residence.
-My response "Damn. Now we have to report again."
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#1946659 - 07/28/14 11:52 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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oh....my.....goodness.....
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#1946679 - 07/29/14 12:53 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Member
Joined: Apr 2013
Posts: 79
FL
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Does anyone have a link to the Small Business Review Panel report? I have been unable to locate a copy of the report even though it's referenced multiple times in the proposed rule.
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#1946681 - 07/29/14 12:57 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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10K Club
Joined: Dec 2000
Posts: 21,293
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#1946682 - 07/29/14 01:00 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Member
Joined: Apr 2013
Posts: 79
FL
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#1946690 - 07/29/14 01:15 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
RR Becca
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Diamond Poster
Joined: May 2013
Posts: 1,782
The Mitten State
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#8 must be for the flood zone, because it looks like that's the only thing missing from just making this the full loan record. Maybe it will be the borrowers blood type. 
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Nonsense wakes up the brain cells.
--Dr. Seuss
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#1947297 - 07/30/14 03:44 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
JWills, CRCM
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Diamond Poster
Joined: May 2013
Posts: 1,069
Compliance Land
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#8 must be for the flood zone, because it looks like that's the only thing missing from just making this the full loan record. Or....favorite ice cream flavor!
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#1947390 - 07/30/14 05:52 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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10K Club
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
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Beginning on page 531 they refer to if the dwelling will be a primary, secondary, etc. dwelling of the applicant or borrower. It does not refer to the owner.
So if a child is borrowing money for a covered purpose and securing the loan with the parent's home they (parents) live in but the parents do not sign the note, only the security agreement, according to the language beginning on page 531 the owner-occupancy would be non-owner occupied.
This reverts back to the reporting requirements prior to the 2004 changes.
Have I missed something?
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The opinions expressed are mine and they are not to be taken as legal advice.
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#1947406 - 07/30/14 06:14 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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So that's a yes - we're going back to the pre-2004 practice of reporting borrower occupancy instead of owner occupancy. Right?
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You call it ADD. I call it multi-tasking.
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#1947421 - 07/30/14 06:24 PM
Re: CFPB Proposed Rule amending Regulation C/HMDA
GTS333
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10K Club
Joined: Jul 2003
Posts: 17,400
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Editorial rant warning! Does the OWNER of the property currently occupy the premises taken as collateral. That's basic, easy to understand English so of course CFPB is going to mess with it! Can you just see the myriad of errors that's going to make? And there isn't a pivot table in existence that will catch that.  I'm tired of this stuff going overboard.
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