Hopefully we will see some sort of very fast proposal. The full Treasury report is at:https://www.treasury.gov/press-center/press-releases/Documents/A%20Financial%20System.pdf
One Page 101, it says:Delay Implementation of HMDA Reporting Requirements
"Fundamental concerns remain about the efficiency of the HMDA regime, borrower privacy, and
competitive harm to lenders through disclosure of proprietary information. The CFPB should
delay the 2018 implementation of the new HMDA requirements until borrower privacy is adequately
addressed and the industry is better positioned to implement the new requirements. The
new requirements should be examined for utility and cost burden, particularly on smaller lending
institutions. Consideration should be given to moving responsibility for HMDA back to bank
regulators, discontinuing public use, and revising regulatory applications."
Some large banks are ready to go and programmed this inhouse, so this is a problem for some. Also, the 2017 submission process is part of the rule, so lets hope that doesn't change at this late date.
The statement about discontinuing public use merits watching. If that came to be, would examiners have access to peer data and financial institutions would not? That needs clarity.