Learn More - Click Here!

Page 1 of 2 1 2
New Reply Thread Options
#2168479 - 03/15/18 08:05 PM S.2155 - passed Senate with 100 amendments but...
Anonymous
Unregistered

Does S.2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act, as passed by the Senate yesterday, still include a provision that banks which originate fewer than 500 hmda closed-end loans per year would not file the expanded 2018 version with 110 data points, and instead would file the regular 2017 version with 26 data points?

It did have such a provision when it was introduced, but, the Senate made 163 revisions/amendments to the amendment before approving it and sending it to the House for a vote. I don't see any easy way to search this. Perhaps someone already knows the answer?

https://www.congress.gov/bill/115th-congress/senate-bill/2155

Return to Top Reply Quote Quick Reply Quick Quote
#2168497 - 03/15/18 08:30 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
fmissle Offline
Platinum Poster
Joined: Jul 2007
Posts: 955
Pac NW
I would wait until after the House passes this or after conference to reconcile the bills before getting too in depth.

If you go to the "Text" tab on that page and select "Engrossed in Senate" you should get the final bill as passed.

Return to Top Reply Quote Quick Reply Quick Quote
#2168734 - 03/16/18 07:03 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

Cool. It's still 500, as passed by the Senate. Now to see how mangled the House will make it.

SEC. 104. HOME MORTGAGE DISCLOSURE ACT ADJUSTMENT AND STUDY.

(a) In General.--Section 304 of the Home Mortgage Disclosure Act of
1975 (12 U.S.C. 2803) is amended--
(1) by redesignating subsection (i) as paragraph (3) and
adjusting the margins accordingly;
(2) by inserting before paragraph (3), as so redesignated,
the following:
``(i) Exemptions.--
``(1) Closed-end mortgage loans.--With respect to an
insured depository institution or insured credit union, the
requirements of paragraphs (5) and (6) of subsection (b) shall
not apply with respect to closed-end mortgage loans if the
insured depository institution or insured credit union
originated fewer than 500 closed-end mortgage loans in each of
the 2 preceding calendar years.
``(2) Open-end lines of credit.--With respect to an insured
depository institution or insured credit union, the
requirements of paragraphs (5) and (6) of subsection (b) shall
not apply with respect to open-end lines of credit if the
insured depository institution or insured credit union
originated fewer than 500 open-end lines of credit in each of
the 2 preceding calendar years.
``(3) Required compliance.--Notwithstanding paragraphs (1)
and (2), an insured depository institution shall comply with
paragraphs (5) and (6) of subsection (b) if the insured
depository institution has received a rating of `needs to
improve record of meeting community credit needs' during each
of its 2 most recent examinations or a rating of `substantial
noncompliance in meeting community credit needs' on its most
recent examination under section 807(b)(2) of the Community
Reinvestment Act of 1977 (12 U.S.C. 2906(b)(2)).''; and
(3) by adding at the end the following:
``(o) Definitions.--In this section--
``(1) the term `insured credit union' has the meaning given
the term in section 101 of the Federal Credit Union Act (12
U.S.C. 1752); and
``(2) the term `insured depository institution' has the
meaning given the term in section 3 of the Federal Deposit
Insurance Act (12 U.S.C. 1813).''.
(b) Lookback Study.--
(1) Study.--Not earlier than 2 years after the date of
enactment of this Act, the Comptroller General of the United
States shall conduct a study to evaluate the impact of the
amendments made by subsection (a) on the amount of data
available under the Home Mortgage Disclosure Act of 1975 (12
U.S.C. 2801 et seq.) at the national and local level.
(2) Report.--Not later than 3 years after the date of
enactment of this Act, the Comptroller General of the United
States shall submit to the Committee on Banking, Housing, and
Urban Affairs of the Senate and the Committee on Financial
Services of the House of Representatives a report that includes
the findings and conclusions of the Comptroller General with
respect to the study required under paragraph (1).
(c) Technical Correction.--Section 304(i)(3) of the Home Mortgage
Disclosure Act of 1975, as so redesignated by subsection (a)(1), is
amended by striking ``section 303(2)(A)'' and inserting ``section
303(3)(A)''.

Return to Top Reply Quote Quick Reply Quick Quote
#2168840 - 03/17/18 04:50 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Quote:
Does S.2155 - Economic Growth, Regulatory Relief, and Consumer Protection Act, as passed by the Senate yesterday, still include a provision that banks which originate fewer than 500 hmda closed-end loans per year would not file the expanded 2018 version with 110 data points, and instead would file the regular 2017 version with 26 data points?

That's my understanding. As fmissile stated, we need to wait & see what the House of Rep's do next before getting too excited. Things could change. I did a video blog on this:

https://www.bankerscompliance.com/blog/
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top Reply Quote Quick Reply Quick Quote
#2179505 - 05/24/18 12:08 AM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

AWWWWWWWWWWWWWWWWWWWWWWWWWWWWWWW

YEEEEEEYAH

House has passed this thing, Senate already did, now awaiting just one last signature to be SIGNED INTO LAW.

HMDA Reform Rollback for low-volume lenders (under 500 something something per year) and that's us baby!!!

Return to Top Reply Quote Quick Reply Quick Quote
#2179599 - 05/24/18 03:54 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
I'm not particularly jumping for joy on this just yet. If they don't tread carefully, they could set us up for one giant mess.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top Reply Quote Quick Reply Quick Quote
#2179613 - 05/24/18 04:34 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
MyKidsMom Offline
Platinum Poster
MyKidsMom
Joined: May 2004
Posts: 634
TEXAS
Any ideas on whether or not this change would affect the 2018 reporting year or just going forward?

Return to Top Reply Quote Quick Reply Quick Quote
#2179633 - 05/24/18 05:00 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
Who knows, they will have to figure out what they are going to do, then reduce it to writing...vendors may have to make necessary changes...If they "simply" remove some of the added data points and keep everything else the same, may not be a big deal. If they dare try to go back to true pre 2018 we are in for a mess.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top Reply Quote Quick Reply Quick Quote
#2179637 - 05/24/18 05:06 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
There is no effective date so presumably it is effective immediately as it is now the law - but you might want to give the CFPB a couple of days to comment.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top Reply Quote Quick Reply Quick Quote
#2179649 - 05/24/18 05:34 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top Reply Quote Quick Reply Quick Quote
#2179650 - 05/24/18 05:35 PM Re: S.2155 - passed Senate with 100 amendments but... rlcarey
NSF, CRCM Offline
Gold Star
NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
Originally Posted By rlcarey
There is no effective date so presumably it is effective immediately as it is now the law - but you might want to give the CFPB a couple of days to comment.


What a mess. I am thankful for the relief, but I am also paranoid about how they can mess something up and make things even more complicated.
_________________________
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

Return to Top Reply Quote Quick Reply Quick Quote
#2179670 - 05/24/18 06:06 PM Re: S.2155 - passed Senate with 100 amendments but... RR Joker
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,572
Originally Posted By RR Joker
If they dare try to go back to true pre 2018 we are in for a mess.

My thoughts exactly.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top Reply Quote Quick Reply Quick Quote
#2179676 - 05/24/18 06:15 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
The only things eliminated are specific loan data requirements. The new demographics will be the same. You just drop some of the data points. Not sure how that is going to be that difficult. The rest of the data points will remain as currently addressed in the current regulation.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top Reply Quote Quick Reply Quick Quote
#2179700 - 05/24/18 07:38 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

OP here: Totally agree with Randy Carey. Let's chillax on this, fam. We have a Republican lawmaking body, Donald Trump for president, and Nick Mulvaney at the CFPB. They will take care of the nightmare created by the voted-but-not-read monstrosity called the Dodd-Frank Act. Let's remember that the DRANK Act was the problem, not the rollback. Our exam team (FDIC) has already told us they will NOT be doing HMDA transaction testing for 2018; they are aware that not even CFPB can explain what the goo is going on with HMDA 2018 rules. This relief/rollback is a blessing! Rejoice!

Return to Top Reply Quote Quick Reply Quick Quote
#2179704 - 05/24/18 07:46 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

OP here: This is why it won't be difficult. The New CFPB (whatever you call it now), I predict, will say:

1. Use the new 2018 LAR tool

2. But hit delete on all the data that is covered by the exemption that became effective 5/23 or 5/24/18

3. They will tell us there will be no penalties or ECOA violations for over-collecting or over-reporting for any time in 2018. They'll give us time to absorb this new law and make changes in June, July, August, etc. If you file something you could have deleted, they won't penalize you. 2018 is a diagnostic year.


I think you'll be told that you can just delete what extra data you collected in 2018, even retroactive to 1/1/18, even thought the law passed in May. Your 26-column LAR will be filed on a 109-column reporting tool. You can very, very easily wipe out all this data if you move it to excel, delete your data from certain columns, and upload it to CFPB. Easy peesy. A 1-hour fix done in Feb. 2019. Not a problem.

I predict also that they'll release a 26-column tool in either 2018 or 2019, so that you can switch to that soon as you can. And they'll give you as much time as you need, without penalizing you for using the 109-column LAR when you didn't have to.

These changes are very good for banks. This is a major victory for common sense regulation of smaller financial institutions, a very historic day. Let's make sure we don't waste the opportunity to celebrate.

Return to Top Reply Quote Quick Reply Quick Quote
#2179833 - 05/25/18 04:28 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,436
Somewhere
OP, which agency do you work for? wink grin

Return to Top Reply Quote Quick Reply Quick Quote
#2181167 - 06/08/18 07:44 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,333
Cape Cod
You can THINK what you want about how this will unfold, but I really don't recommend changing anything unless and until the CFPB/BCFP offers guidance. They are going to have to amend the regulation in any event, but I'm guessing they are deliberating now about how to implement this amendment to the law. Amending a law requiring data collection on an annual basis without providing an effective date for the amendment was a misguided move on their part, IMHO.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top Reply Quote Quick Reply Quick Quote
#2182311 - 06/19/18 04:43 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

OP here: I don't work for a regulator, but for a smallish bank that will benefit tremendously by the rollback of this poorly-thought-out 109-column LAR garbage.

ICBA's summary shows that certain provisions of S. 2155 require rulemaking, while others do not. The HMDA provision does not require rulemaking as is effective immediately.

This is a unique thing during my few (15 or so) years in banking; I can't recall a law that didn't require rulemaking, so, yeah, the industry is confused...what do we do? How do we comply, with no rulemaking? It's crazy. But it's still a joyous occasion.

What I'm hoping to see is an announcement to be made very, very soon (this week would awesome) by CFPB/BCFP or whatever they call it now, telling us it's effective on X date and how to proceed: whether that means a new LAR tool, a homemade excel LAR, emailing an encrypted .dat file like we used to, or whatever - even using the 109-column LAR would work. Bankers just need the BCFP to step forward and tell us, immediately, what we are supposed to be doing.

In my state, every banker I know is still collecting year 2018 demographics and other byzantine/obscure loan details that we already know we will not have to report. We are wasting a ton of time complying with a law that Congress rendered obsolete, effective almost a month ago now.

CFPB are you listening? Help!

Return to Top Reply Quote Quick Reply Quick Quote
#2182327 - 06/19/18 06:00 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
Originally Posted By Anonymous
In my state, every banker I know is still collecting year 2018 demographics and other byzantine/obscure loan details that we already know we will not have to report. We are wasting a ton of time complying with a law that Congress rendered obsolete, effective almost a month ago now.


S.2155 is not going to change the gathering of the 2018 demographics information for anyone. That is not part of the relief. As far as collecting "other byzantine/obscure loan details", they are all in the file already. Whether you choose to continue to organize them in preparation for HMDA filing is the only question. You are not gathering any additional information that is not already in a typical mortgage file for the sake of HMDA reporting.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top Reply Quote Quick Reply Quick Quote
#2182481 - 06/20/18 06:47 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

OP here: I'm really wary of people thinking new HMDA is not a big deal. I suspect you haven't written a LAR in a long time if you think that's the way it is. I don't have any "typical mortgage" files, but we're required to report HMDA data. I don't want any non-bankers out there reading this thread to suffer under the false impression that new 2018 HMDA is merely a matter of gathering data already present in our files. For us, like many other HMDA-reporting banks, it certainly is not so simple.

I work at a bank that does a ton of commercial loans. A typical file will have, for instance:

We often have 2 to 15 properties securing the loan, some of which are AOC with no stated value, and CFPB wants a combined total property value on all of them.

No LTV stated anywhere, yet somehow we approved the loan. We used a "margin" of up to X%. Is that our reportable LTV? Maybe. We also have a lot of construction-related deals where property value and LTV are not in file or even necessarily relevant. They may also have multiple LTVs expressed for different stages of the loan.

We have a scanned image of signed document somewhere that will express the interest rate, loan term, intro rate period, etc. But these aren't just fields in my system, where I can tell the system to generate a LAR that captures those numbers. I have to read that grainy, scanned, signed document, and manually type in the answers to each LAR field.

Balloon payment, yes or no? Well, let me go find another scanned document and read it, and see if the final payment is more than a certain amount over the "regular" payments, using a Reg Z consumer definition for this commercial loan. Then add a yes or no code (1 or 2) corresponding to the deduced answer. There is no "balloon yes" field in my system. This is manual.

I have no idea what the options under Manufactured Home Property Type even mean; ditto for Manufactured Home Land Property Interest. We do some mobile home lending - typically, for an entire mobile home park. None of the options make any sense under our state law.

Total Units, ha ha, that's a good one. 12 properties, some of which have appraisals, most of which have multiple units. Sure, let me just go pull up images - from appraisals and, when those aren't present in the file (perhaps because it was denied?) from Google Maps - and count doorways and extrapolate which doorways look like individual units. Add all that up, and, nice, an hour later, I have data for a single field on the LAR. Then I need to know how many are income-restricted under any local, state, or federal law.

NMLSR - I pull it from a list and add it manually to the LAR. After looking up a specific spot to see who the officer was on that deal. Not a field in our system.

ULI - manual process using CFPB website tool. I then copy and paste this 28- to 38-digit number, which exists solely to satisfy CFPB regs, into our LAR, in lieu of having a LAR field that gives me a straightforward loan number or application number to which I can refer during the 10 to 50 repeat trips to this LAR row I'm going to be making this year.

I manually obtain online, and paste the weird, duplicative geocoding data so that we have a 5 digit "county code" (showing state and county code) and an 11-digit "census tract" consisting of the same 5 digits as the other field, plus the usual 6-digit census tract, with the decimal point manually removed, every time.

I manually convert every single date from 6/20/2018 to CFPB's silly 20180620 format, on several columns for every entry.

When borrowers are natural persons, I manually type the codes for the thirty-six fields corresponding to demographics.

I manually correct every dollar figure so that we have loan amount expressed without commas but with decimals (62000.00 for 62,000.00) but property value has to have the information rounded with no decimals (150000 for 150,000.00) while loan amount has to be expressed to the penny with no rounding, with commas and decimals (1,815,215.94 for 1,815,215.94). If you were intentionally trying to cause LAR errors, you couldn't do much better than making 3 ways to write a dollar figure on one row. That is, unless, you could find over a dozen ways to say "not applicable"...

I constantly refer to a chart to cope with the 13 different ways that HMDA 2018 has for expressing a simple "NA." For instance, if visual observation of the ethnicity of the applicant is not applicable, that's code 3. But if visual observation of the ethnicity of the co-borrower is not applicable because there was no co-borrower, that's code 4. If the borrower's race is not applicable because the borrower is an LLC, that's code 7. But if the co-borrower's race is not applicable because there is no co-borrower, that's code 8. If the borrower did not choose a 2nd race selection, that selection is inapplicable, so express that with a blank field, as opposed to the "NA" you would use to say that income is not applicable. If HOEPA status in not applicable, well, that's code 3. If the credit score of the borrower is for some reason not applicable (it was not used in the credit decision, or the borrower is an entity) then that's code 8888. If the co-borrower's is not applicable because there is no co-borrower, that's 9999. Recently I counted that there are 13 unique ways to express "NA," on the LAR. Absolutely none of these absurd codes are already present in my loan files.

--------------------------------------------------------------

Reverting to year 2017 standards will mean reporting "Asian" but not "Korean," right? So we are in fact collecting demographics info that we are exempt from reporting, aren't we? And many of these obscure data points have no relevance to me, as a HMDA staffer, other than to satisfy the new 2018 HMDA LAR requirements. So yes, I'm certain that the industry needs immediate relief and an immediate announcement from the CFPB about how to cope with S 2155.

Return to Top Reply Quote Quick Reply Quick Quote
#2182484 - 06/20/18 07:16 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
TMatt87 Offline
Diamond Poster
TMatt87
Joined: May 2011
Posts: 1,907
Idaho
I agree that the 2018 rules are a burden. However, it sounds like you are blaming your institution's system and process limitations on the rule. We have a bunch of commercial loans, many of which have several properties as collateral, and at most, it takes me 30 minutes per file. If you are having to manually input all these fields or make changes for formatting, you should look into a HMDA management software that does that all for you.

The new rules are a pain, but certainly not the end of the world. If you're expecting swift action from a government agency, you will likely be disappointed.
_________________________
All opinions are my own, not my employer's

Return to Top Reply Quote Quick Reply Quick Quote
#2182487 - 06/20/18 07:25 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,644
The Swamp
This ^^^
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top Reply Quote Quick Reply Quick Quote
#2182524 - 06/20/18 10:19 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
"Reverting to year 2017 standards will mean reporting "Asian" but not "Korean," right? So we are in fact collecting demographics info that we are exempt from reporting, aren't we?"

This is not a reversion to the 2017 rules, you would only be exempt from the following, and the new demographics is not one of them:


(5) the number and dollar amount of mortgage loans grouped according to measurements of-

(A) the total points and fees payable at origination in connection with the mortgage as determined by the Bureau, taking into account 15 U.S.C. 1602(aa)(4);

(B) the difference between the annual percentage rate associated with the loan and a benchmark rate or rates for all loans;

(C) the term in months of any prepayment penalty or other fee or charge payable on repayment of some portion of principal or the entire principal in advance of scheduled payments; and

(D) such other information as the Bureau may require; and



(6) the number and dollar amount of mortgage loans and completed applications grouped according to measurements of-

(A) the value of the real property pledged or proposed to be pledged as collateral;

(B) the actual or proposed term in months of any introductory period after which the rate of interest may change;

(C) the presence of contractual terms or proposed contractual terms that would allow the mortgagor or applicant to make payments other than fully amortizing payments during any portion of the loan term;

(D) the actual or proposed term in months of the mortgage loan;

(E) the channel through which application was made, including retail, broker, and other relevant categories;

(F) as the Bureau may determine to be appropriate, a unique identifier that identifies the loan originator as set forth in section 5102 of this title;

(G) as the Bureau may determine to be appropriate, a universal loan identifier;

(H) as the Bureau may determine to be appropriate, the parcel number that corresponds to the real property pledged or proposed to be pledged as collateral;

(I) the credit score of mortgage applicants and mortgagors, in such form as the Bureau may prescribe; and

(J) such other information as the Bureau may require.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top Reply Quote Quick Reply Quick Quote
#2182540 - 06/21/18 12:32 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

I think I am unclear on what S.2155 actually does. Does it:

a) Provide exemption for some (or all?) of the new HMDA items specified by Dodd-Frank?
b) Or undo only the discretionary data points invented by CFPB?
c) Or both of the above?
d) Or create a 3rd list, and exempt only those?

Randy’s response indicates that we would be exempt from numerous items that were specifically spelled out in Dodd-Frank, that is, not the discretionary items dreamed up by CFPB, but rather, items from the actual text of Dodd-Frank, including:

1. Points & Fees
2. Difference between APR and benchmark rate
3. Prepayment penalty
4. Property Value
5. Intro rate period
6. Whether terms include non-amortizing features
7. Term in months
8. Channel
9. NMLS of originator
10. Universal loan ID.
11. Parcel Number
12. Credit Score

My understanding was Dodd-Frank also required reporting of:
13. Applicant Age, and
14. Postal Address,

…but I could be mistaken. Old HMDA was 26 columns of data. With Dodd-Frank changes only (and without any added discretionary items), we’d be looking at some 39 data points, representing, I believe, 44 data columns total (since some items must be reported for each of two applicants), if CFPB had only added the data points specified in Dodd-Frank.

However, CFPB used the phrase “such other information as the Bureau may require” to change the LAR from the 39 to 44 columns it would have been, up to the full 109 columns it is today. Following are the data points that I believe CFPB initially added under its own discretion, and these would be, I thought, also subject to exemption via S. 2155 for smaller institutions:

15. All the new ethnicity, race, and sex choices, as well as whether they were collected visually (reducing GMI back to 6 columns of data per borrower, instead of this year’s 18 columns per borrower)
16. The new choices in Loan Purpose (elimination of having to distinguish between cash out refi vs. refi with no cash out)
17. Construction Method – though this is really just another way of saying property type
18. Change to occupancy type (from “owner occupied as principal residence vs. NOT owner occupied as a principal residence" to the more complex “principal vs. secondary vs. investment” which clouds the question of whether the loan is consumer or commercial when “investment” is chosen)
19. Making county code 5 digits, census tract 11 digits – though this probably won’t change since FFIEC is transitioning this to CFPB - and maybe this is what CFPB is using as "parcel number" because I don't see "parcel number" anywhere in the 2018 LAR filing tool.
20. Credit Scoring Model code & free-form – though I suspect we’ll have to keep this, otherwise the Credit Score is rendered meaningless, isn't it?
21. Mandatory reporting of reasons for denial (this could go back to optional)
22. Total Loan Costs
23. Origination Charges
24. Discount Points
25. Lender Credits
26. Interest Rate
27. Debt-to-Income Ratio
28. Combined Loan to Value
29. Balloon Payment
30. Interest-only payments
31. Manufactured Home Property Type
32. Manufactured Home Land Property Interest
33. Total Units
34. Multifamily Affordable Units
35. Initially Payable to Institution
36. Automated Underwriting results for each borrower (eliminates 12 columns)
37. Reverse Mortgage yes/no
38. Open-end line of credit yes/no
39. Business or commercial purpose

Return to Top Reply Quote Quick Reply Quick Quote
#2182541 - 06/21/18 12:34 PM Re: S.2155 - passed Senate with 100 amendments but... Anonymous
Anonymous
Unregistered

P.S. Correction to my post above - Randy's response includes items 1 through 12 plus two references to discretionary items, which to me means 1 through 12, plus, 15 through 39 would be subject to exemption, whereas Randy is saying that demographics collection would not be impacted by S. 2155.

Return to Top Reply Quote Quick Reply Quick Quote
Page 1 of 2 1 2
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale