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#2179079 - 05/22/18 01:53 PM
Re: HMDA bill passes House
Truffle Royale
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10K Club
Joined: Nov 2002
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The Swamp
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It's maddening.
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2179084 - 05/22/18 02:24 PM
Re: HMDA bill passes House
Truffle Royale
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Diamond Poster
Joined: Jan 2010
Posts: 1,028
Utopia
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I agree, sometimes undoing can cause more stress than it's worth. I am absolutely struggling right now reviewing the first quarter LAR because of formatting and a new person getting there head around it. It's a bear!
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#2179086 - 05/22/18 02:26 PM
Re: HMDA bill passes House
Truffle Royale
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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If Congress ever wanted my opinion on bank regulations (hahaha), i would tell them this:
Make up your mind what you want, one way or the other--at the end of the day, i don't really care. Just make up your mind and be done with it. Bank regulations shouldn't be subject to political whims every 2 years--sound banking is sound banking and that doesn't/shouldn't change.
So even if you want the most onerous regulations imaginable, at the end of the day, that's fine so long as you don't say "just kidding" in 6 months.
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#2179087 - 05/22/18 02:27 PM
Re: HMDA bill passes House
Truffle Royale
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Power Poster
Joined: Sep 2010
Posts: 2,670
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raitchjay for congress?
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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2179088 - 05/22/18 02:35 PM
Re: HMDA bill passes House
Truffle Royale
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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I'd get zero votes....lol. I can't play the politics game, and there's a reason i'm in compliance and not sales.
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#2179092 - 05/22/18 02:40 PM
Re: HMDA bill passes House
raitchjay
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Power Poster
Joined: Sep 2010
Posts: 2,670
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there's a reason i'm in compliance and not sales. I think that is true for most of us.
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Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2179221 - 05/22/18 10:00 PM
Re: HMDA bill passes House
Truffle Royale
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New Poster
Joined: Jan 2016
Posts: 23
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And S. 2155 has now passed the house. This will be interesting to see how they will undo some of this..
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#2179223 - 05/22/18 10:05 PM
Re: HMDA bill passes House
Truffle Royale
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Gold Star
Joined: Sep 2016
Posts: 351
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So.....does this mean the exemption for HMDA reporting is still at the 25 threshold? I was hoping that was increased in this bill.
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#2179224 - 05/22/18 10:21 PM
Re: HMDA bill passes House
Truffle Royale
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Gold Star
Joined: Jun 2010
Posts: 257
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There's no blanket exemption to HMDA reporting in the bill. The change would be to allow insured depository institutions (banks and CU's) to only report the smaller pre-2018 HMDA data set. At least that's the high-level summary, without all the inherent problems discussed in this thread.
Hopefully the CFPB will have something ready to go by the time the President signs this into law.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.
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#2179226 - 05/22/18 11:17 PM
Re: HMDA bill passes House
Truffle Royale
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10K Club
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Posts: 40,086
Cape Cod
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Passed the House and on its way to the White House.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2179251 - 05/23/18 12:41 PM
Re: HMDA bill passes House
Truffle Royale
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The only thing that makes any sense to me is NOT to go back to pre 2018, but to eliminate some of the additional data points. I cannot for the life of me see having 2 totally different ways of reporting with separate definitions, water falls and everything else. THAT would be a nightmare for sure!
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2179256 - 05/23/18 12:45 PM
Re: HMDA bill passes House
Truffle Royale
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Power Poster
Joined: Oct 2000
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Soaring over Georgia
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Still many questions to be answered. Dual reporting system? What about the fields that weren't added by Dodd-Frank, but rather were added by BCFP under their discretionary authority? Will BCFP roll those back too now that there is new leadership at BCFP? I so much would rather Congress had just created a new bright line test for HMDA applicability altogether. This will be a mess.
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#2179259 - 05/23/18 12:58 PM
Re: HMDA bill passes House
Truffle Royale
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The Swamp
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Beech, after I heard my recent examiners tell me just what all that data is used for that has NOTHING to do with housing or FL, I'm not really surprised the hopeful bright line didn't happen.
Last edited by RR Joker; 05/23/18 12:58 PM.
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My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2179273 - 05/23/18 01:46 PM
Re: HMDA bill passes House
Truffle Royale
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Diamond Poster
Joined: Aug 2012
Posts: 1,709
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Woof! I wonder if the definition will include bank and affiliates in the calculation of the 500.
Either way, I'm putting this first quarter scrub on the back burner to attend to other things. Stupid HMDA!
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#2179285 - 05/23/18 02:23 PM
Re: HMDA bill passes House
Truffle Royale
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Power Poster
Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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I wonder if the definition of 500 'covered' loans will be the one from pre- or post-2018 rules.
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#2179286 - 05/23/18 02:27 PM
Re: HMDA bill passes House
Truffle Royale
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Gold Star
Joined: Jun 2010
Posts: 257
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NormanPaperman - There's actually no use of the "covered" language in the bill as it stands. Read literally, it simply says if you originated fewer than 500 open or closed-end loans in each of the prior two years, you collect the pre-Dodd-Frank data points.
Beechflyboy - The discretionary items were technically added as part of the provisions in Dodd-Frank that are exempted by this bill, so I believe it would cover those as well (though, CFPB rulemaking will hopefully solve all this).
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#2179301 - 05/23/18 02:51 PM
Re: HMDA bill passes House
Truffle Royale
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Galveston, TX
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The discretionary items will be rolled back, as they were added in paragraphs 5 and 6 under "such other information as the Bureau may require" which will no longer apply to those reporters under the new thresholds.
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#2179308 - 05/23/18 03:21 PM
Re: HMDA bill passes House
GTS333
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Joined: Sep 2016
Posts: 351
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So they removed the exemption completely? If we have 1 HMDA loan based on the 2018 definitions we have to report (but using the pre-2018 data)? I thought the regulatory relief was also going to raise the exemption from the old 25.
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#2179316 - 05/23/18 03:44 PM
Re: HMDA bill passes House
rlcarey
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Joined: Jan 2010
Posts: 1,028
Utopia
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The discretionary items will be rolled back, as they were added in paragraphs 5 and 6 under "such other information as the Bureau may require" which will no longer apply to those reporters under the new thresholds. I hope I am understanding this correctly. Only the fields that DF required would be the data compiled and reported for those of us that do not fall under the 500 or less category?
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#2179318 - 05/23/18 03:49 PM
Re: HMDA bill passes House
Truffle Royale
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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I'm guessing that the current exemption levels in the Reg will apply to all filers, and those filers making fewer that 500 closed-end mortgage loans or 500 open-end lines will complete the short list (pre-2018 list) of data fields. But we have to wait to see how the Bureau implements the change in the law.
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#2179321 - 05/23/18 03:57 PM
Re: HMDA bill passes House
Truffle Royale
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Power Poster
Joined: Oct 2009
Posts: 9,232
OK
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I've never really had to worry about HMDA thresholds before (we don't do HELOCs, we easily surpassed the 1 or 25 mortgage loan level to be a HMDA reporter)...anyway.....the 500 closed-end mortgage loans....is that 500 HMDA REPORTABLE closed-end mortgage loans..or just 500 closed-end mortgage loans?
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#2179323 - 05/23/18 04:03 PM
Re: HMDA bill passes House
Truffle Royale
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Diamond Poster
Joined: Jan 2010
Posts: 1,028
Utopia
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Truffle, that is my thought, unless the new rule will eliminate the data fields that the CFPB added at their discretion. Then there would be some relief from the 100+ that I am currently trying to review for first quarter.
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#2179338 - 05/23/18 04:26 PM
Re: HMDA bill passes House
Truffle Royale
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Diamond Poster
Joined: Aug 2012
Posts: 1,709
48.934476, -114.343735
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My exact words to my boss the other day (he's a cool boss).
"This new HMDA rule is eating my [censored] lunch."
This was the first real kick (substantial) in the pants I've felt from Dodd-Frank for a community bank in terms of actual workload increased. Sure, TRID and ATR stuff takes extra work and monitoring, but this deal adds exponential hours in the seat.
I'll welcome the relief.
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Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.
CRCM
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#2179340 - 05/23/18 04:30 PM
Re: HMDA bill passes House
Truffle Royale
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Diamond Poster
Joined: Jan 2010
Posts: 1,028
Utopia
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Norm:
I agree, I told my boss yesterday "I could cry" those are not words that I use in the work place.
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