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#2161017 - 01/19/18 03:12 PM HMDA bill passes House
Truffle Royale Offline

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From today's ABA Bulletin:
Quote:
House Passes ABA-Backed HMDA Reporting Bill
The House last night passed an ABA-backed bill that would ease reporting burdens associated with the expanded Home Mortgage Disclosure Act data collection. H.R. 2945 -- introduced by Rep. Tom Emmer (R-Minn.) -- passed on a bipartisan 243-184 vote.

Emmer's bill would prevent any regulatory enforcement or judicial action from being taken for data collection errors or other difficulties related to the new HMDA rules until 2019. It would also prohibit the reporting of any HMDA data collected until 2020.


Can someone translate the last sentence for me?

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#2161019 - 01/19/18 03:22 PM Re: HMDA bill passes House Truffle Royale
Sinatra Fan Offline
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Just a guess on my part, but I think it means the CFPB may not publicly report any HMDA data it collected from HMDA-reporters until 2020 (instead of making it publicly available in late 2019).
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#2161022 - 01/19/18 03:28 PM Re: HMDA bill passes House Truffle Royale
Truffle Royale Offline

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or...could it possibly mean that we wouldn't have to file a HMDA report for 2018 data???? (I know, ♪♫ Dream a Little Dream ♫♪)

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#2161027 - 01/19/18 03:33 PM Re: HMDA bill passes House Truffle Royale
Sinatra Fan Offline
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BTW, the ABA news byte contains a typo. The bill number is actually HR 2954.
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#2161074 - 01/19/18 06:11 PM Re: HMDA bill passes House Truffle Royale
LaLendingLady Offline
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HR 2954 amends the transactional coverage exemptions to 500 for closed-end loans & 500 for open-end loans in the 2 preceding years. I think there would have to be reconciliation with a similar bill passed in the Senate then signed by the President before it becomes law. The original bill was amended. The original text of the bill was for 1000 closed-end & 2000 open-end loans. I suppose they are trying to align it with S.2155 in the Senate which has made it out of committee and to be schedule for the Senate floor. ????

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#2161083 - 01/19/18 06:32 PM Re: HMDA bill passes House Truffle Royale
rlcarey Online
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Good luck getting S. 2155 to go anywhere.
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#2166592 - 03/02/18 10:28 PM Re: HMDA bill passes House Truffle Royale
LaLendingLady Offline
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S. 2155 is scheduled for a floor vote next week in the Senate. We shall see. Optimistically hopeful and pessimistically realistic over here.

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#2166747 - 03/05/18 09:20 PM Re: HMDA bill passes House LaLendingLady
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Can you put this in more..."for idiots" terms...please?
Last edited by Winning; 03/05/18 09:28 PM.
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#2169186 - 03/20/18 05:11 PM Re: HMDA bill passes House Truffle Royale
MScarn6942 Offline
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https://www.congress.gov/bill/115th-congress/senate-bill/2155

Does this mean that S. 2155 passed the Senate now? Is that good news for small bank HMDA?
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#2169234 - 03/20/18 07:21 PM Re: HMDA bill passes House Truffle Royale
RVFlyboy Offline
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Yes, S.2155 passed the Senate last week. Is that good news for small bank HMDA? To be determined. The bill does raise the threshold from 100 to 500 for both closed-end and open-end loans, but only as applies to the additional data points required by Dodd-Frank. And it still depends on what the House does with their version and what works out in reconcilement. And then, it depends on how the CFPB implements a revised rule to address this. What this bill does is put small banks with low volumes of HMDA loans back to pre-2017 HMDA from a statutory perspective. The new data points added by Dodd-Frank would no longer be applicable for those institutions. But what about the additional data points that were not in Dodd-Frank but were added by CFPB? And how does CFPB propose to manage two different HMDA reporting systems? Those are unanswered questions as of yet.
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#2169283 - 03/20/18 09:30 PM Re: HMDA bill passes House Truffle Royale
David Dickinson Offline
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Watch my video blog about S2155:
https://www.bankerscompliance.com/hmda-drive-update/

As Beech says - there are LOTS of questions to be answered.
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#2169550 - 03/22/18 02:12 PM Re: HMDA bill passes House Truffle Royale
John Burnett Offline
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Nice job, David! The urgency of your message was enhanced by the fact you recorded that vlog on the road after the convention.
Last edited by John Burnett; 03/22/18 02:12 PM.
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#2169595 - 03/22/18 04:24 PM Re: HMDA bill passes House Truffle Royale
David Dickinson Offline
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Thanks John. I'm not a marketing guy but that blog seems to have gone over well. More than 2000 views on LinkedIn alone. I'll have to do more of those!
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#2169603 - 03/22/18 04:48 PM Re: HMDA bill passes House Truffle Royale
MScarn6942 Offline
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David - that was excellent. You could (should? smile ) start a series of those! Thanks for clarifying David and Beech.
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#2169621 - 03/22/18 05:24 PM Re: HMDA bill passes House Truffle Royale
RR Joker Offline
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Finally had a chance to view it...I see a potential trainwreck with some of that 'relief'.
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#2169634 - 03/22/18 06:01 PM Re: HMDA bill passes House Truffle Royale
RVFlyboy Offline
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Yes. Now is the time to contact your Congressional representatives in the House as they will be taking up legislation to tie in with this and they're going to be back in your districts for the next 2 weeks as the House is on Easter recess.. Let them know the kinds of problems this is going to create and urge them to consider amending their bill to simply exempt from HMDA altogether those institutions with few that 500 closed-end or 500 open-end dwelling-secured loans in each of the preceding two years, not just exempt them from the additional Dodd-Frank added components. Explain to them the problems that will result in having the CFPB having to manage two different HMDA systems if the bill goes through in its current format.
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#2169641 - 03/22/18 06:12 PM Re: HMDA bill passes House Truffle Royale
RR Joker Offline
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It's not just those changes. The appraisal exemptions and elimination of some elements of ATR/QM could cause 'loose lending' once again as well. eek
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#2169657 - 03/22/18 06:33 PM Re: HMDA bill passes House Truffle Royale
RockChucker, CAMS Offline
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Appraisal exemptions I am not so concerned about as it only applies to rural areas. Many times we do these types of loans and there are not quality comparables so appraising the value is very difficult or difficult to support. Plus it is limited to properties under 400k.
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#2169678 - 03/22/18 07:13 PM Re: HMDA bill passes House Truffle Royale
RR Joker Offline
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Which is about 100% of our portfolio. smirk
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#2169740 - 03/22/18 09:12 PM Re: HMDA bill passes House Truffle Royale
David Dickinson Offline
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Quote:
David - that was excellent. You could (should? smile ) start a series of those! Thanks for clarifying David and Beech.

Thank you for your kind words. We plan to do many more of these types of videos. There's another coming out tomorrow (or soon) by Jerod Moyer on TRID. Subscribe to our blog at our website. You simply register to get signed up.
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#2169870 - 03/23/18 04:01 PM Re: HMDA bill passes House RVFlyboy
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Raise the threshold to 1000 - like the original bill contained - then it will help more institutions.

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#2178998 - 05/21/18 07:25 PM Re: HMDA bill passes House Truffle Royale
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Is anybody following this bill as it moves to possible vote this week in the house? Just curious about how this might effect our HMDA report if it actually does get passed.

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#2179009 - 05/21/18 07:44 PM Re: HMDA bill passes House Truffle Royale
Sunshine Lady Offline
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I know that the vote is tomorrow, so fingers crossed that it does pass (My Opinion only) and then that if it does, there is not a long waiting period for it to go into effect.
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#2179022 - 05/21/18 08:25 PM Re: HMDA bill passes House Truffle Royale
GTS333 Offline
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I'm torn on this one. The bill as written in Congress is ridiculously broad. Looking at HMDA specifically, I would assume the CFPB is going to have to issue some rule to clarify how to handle what basically amounts to a separate data set for smaller HMDA lenders.

It's easy to say you just "go back" to pre Dodd-Frank HMDA, but that's not a clean process. For example, does that also include modifications, like the collection of rate spread? (I.e. do we go back to collecting that only on HPML loans and not all Reg. Z loans?) What about government monitoring information, do we go back to only collecting the aggregate categories, but we'll still need to collect age (as that was missed in Senate Bill 2155)? Do the GSE's need to issue new guidance to allow us to not use the new GMI addendum they created? Ugh, what a mess.

As for time period to go into effect, there isn't a specific effective date spelled out in Senate Bill 2155 for the HMDA provisions, so I think those go into effect immediately upon the President's signature. So, no time for the CFPB to actually issue any clarifying rules unless it's super on the ball (not likely).

...Maybe I'm overacting, but this feels like it hasn't been thought through all that well do me.
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#2179027 - 05/21/18 08:46 PM Re: HMDA bill passes House Truffle Royale
raitchjay Offline
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Yeah, i can't say i'm a big fan of 'after-the-fact' relief. Sort of like telling a relucant astronaut he doesn't have to go to the moon after all when he's halfway to the moon.
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