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#2134208 - 06/14/17 12:08 PM Treasury Recommends HMDA Postponement
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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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.
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#2134219 - 06/14/17 01:03 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
MBTCompliance Offline
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Maybe we will get some relief between that and the Home Mortgage Disclosure Adjustment Act (S. 1310) introduced by Senators Rounds and Heitkamp. The regulatory burden is being discussed on multiple levels.

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#2134302 - 06/14/17 03:42 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
David Dickinson Offline
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I recommend continuing to prepare for the changes as if they will be effective 1/1/18. Hopefully we can get some things removed, clarified and/or delayed, but don't count on it.
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#2134309 - 06/14/17 03:54 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
Truffle Royale Offline

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Not counting on it, David, but definitely emulating the turtle more than the hare right now.
Hadn't planned on training till closer to use time anyway.

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#2134333 - 06/14/17 05:12 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
bOaty Offline
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I am getting ready to make an offer to hire someone as an additional person to handle the increase in volume that we will have due to reporting HELOCs. I can't wait any longer as they need to get up to speed and help with the implementation and testing. If this gets delayed I have no idea what I'm going to do with an extra body.

Oy vey.
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#2134336 - 06/14/17 05:35 PM Re: Treasury Recommends HMDA Postponement bOaty
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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This is very tough at this point in time.
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#2134346 - 06/14/17 06:23 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
RR Joker Offline
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You can send them to me, bOaty smile I'm not sure whether to just go ahead and sink...or try to swim, knowing sinking is the end result no matter what.
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#2134349 - 06/14/17 06:26 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Maybe I could use them part time. :-)
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www.kaybeescomplianceinsights.com

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#2134362 - 06/14/17 07:24 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
bOaty Offline
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I can't find anyone with experience here in my neck of the woods so they are pretty green, don't know if you'd want that!!

We have created front line training and are creating the test script for testing Encompass. Next will be the script for DecisionPro (pending the new release) and the data collection software. Countless hours of research and tool development to bring four business units, two LOS systems and a manual collection system all into the data software

That's OK, I didn't have anything better to do this year. smirk
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#2134367 - 06/14/17 07:35 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
Kathleen O. Blanchard Offline

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I can train them!

I have been pondering possible approaches to the proposed delay. Here is one:

Move forward with new format and existing fields but new rules and guidance for those fields (which in many cases is more informative). We shall see but that could work. So, a combo approach. For example, new occupany reporting rules, new geocoding rules, new gross annual income rules.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2134388 - 06/14/17 07:57 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
bOaty Offline
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Chillin an grillin
If only they will take your recommendation!

There are so many good things that would be helpful.
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#2134391 - 06/14/17 08:04 PM Re: Treasury Recommends HMDA Postponement Kathleen O. Blanchard
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
Indeed. We would have the new ag expanded exclusion, etc.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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