Is it too late to rollback the changes coming in 2018? HMDA seems to be going from a nice, friendly little fun regulation to a nightmare, and i would like to see it saved from that fate.

I think there are many good things in the new HMDA rules. Lots of clarifications, applying it home equity (vs. just purchase, refinance and home improvement), but there are too many data issues that were not mandated in the Dodd-Frank Act. These should be repealed. Also, since all ag loans are exempt and all non-dwelling commercial purpose loans are exempt, why not also exempt the refinancing of all non-dwelling commercial purpose loans? They are exempt the first time, but not if the loan is refinanced? I don't believe the CFPB intended this.

I think this and the small business collection proposition are two of the most burdensome regulations heading down the pipe for bankers (specifically community banks). We are already invested in TRID and QM/ATR rules, and I believe those have both done good things for the public interest and have been relatively easy (comparatively speaking) for bankers to roll out.

The growth of HMDA is nothing more than an addiction to data collection and it is a significant burden on many banks already. The growth of HMDA data collection should be of paramount concern for any banker.

I agree that it's too late (and as Norman says, probably not beneficial for banks or consumers) to change TRID or ATR. I can live with both of those as currently constructed.

Agreed with both of the above.

The Homeownership Counseling Disclosure though, there is one I think we can all agree can go, and be done so quite quickly and easily.

HMDA, CRA, Small Business reporting might have a snowballs chance. Counseling disclosure directly impacts information provided to the consumer. I don't think we will see much of that.

I think that much of what the CFPB added to DFA's HMDA overhaul is simply self-perpetuating bureaucracy. That stuff can go. However, I do agree with David's points about the clarifications of old confusion points and inclusion/exclusion issues.

Yes, it is primarily the expansion of the fields from what.....25-30 to 85-90 that is my beef.

David, please clarify the statement above regarding commercial non-dwelling secured loan above...What non-dwelling secured loans would be non reportable the first time, but reportable at refinance? The only thing I can think of that fits that scenario is a dwelling secured equity loan subsequently refinanced...but nothing non-dwelling..

I didn't say non-dwelling SECURED. I said non-dwelling commercial purpose. For example, if I borrower money for business operating expenses and the lender takes my house as collateral, that is exempt from HMDA 2018 the first time. But if I refinance that loan, it is reported.

Sorry, David...my grey matter did not interpret it that way...but I gotchu...equity loan later refi'd...secured by a dwelling.

I'm going to start a GoFund Me page to send David, Andy, John, Randy, and Dan to DC to have a meeting with the Don.

Any [censored] about APR and I'll send in Richard as well!

Joker, I didn't understand that comment either until David made his clarification. I was thinking that I had missed something!

Yeah, I think 'purpose' and 'commercial' were reversed, which let to an entirely different interpretation.

I was at an FRB conference a few weeks ago that showed that 71% of the banks the Fed examines get cited for HMDA errors....so let's see....let's expand HMDA fields exponentially and expect perfection in reporting.....there are some changes under the DFA that i actually understand, but this is the height of silliness.

On the subject of proposed changes that i would like to see: We're a HMDA reporter only because we have one branch in an MSA--about 10-20% of our HMDA LAR is those loans--the other 80-90% of the loans on our LAR are not in that MSA, or any MSA for that matter. I would like to see a proposal that only loans in MSA's must be reported on the LAR--in the grand scheme of HMDA, it would be a small percentage of loans nationally that went away--but it would drastically reduce my workload and i'm sure there are others like me who are stretched thin and need to devote time elsewhere.

^^^me! me!!! It's definitely 90% of the loans now on my LAR that would drop off if I only reported those in my one little MSA. That would be so SWEET!

Back to offering my daily sacrifice to the gods that POTUS gets one thing right and repeals at least the CFPB additions to 2018 HMDA. Adding, give or take, a dozen new fields (depending on what you read, the number is 11 to 19) would be so much more doable than all the carp the CFPB loaded on.

If I only reported in my one MSA, I'd say 98% or more of mine would go away.

It only makes sense...if you don't have a branch in an MSA--you aren't a HMDA reporter.....so why should you have to report non-MSA loans? There are TONS of banks out there not in an MSA that aren't HMDA reporters...NONE of their non-MSA loans are getting reported...why do mine have to be reported?

I totally agree. It's a burden on us little guys...just because we made the "error" of building a branch in a corner of an MSA location without realizing the ramifications of doing so.

For some reason, our non-MSA loans are "special" and have to be reported.

Well, you know...if you are big enough to have a branch in an MSA...and you make 10 loans there...you must be big enough to report the other 450 that are NOT in an MSA.

It really is very stupid.

Totally agree...