It appears as though this bill will be getting onto the Senate floor next week. Right now, it also appears as though it has the bipartisan support needed in order to pass. If it does, it's expected the House will pass also and the President would sign.

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

This does quite a bit, but the parts that are important to me are:

QM if held in portfolio (and meets other minor requirements)
HMDA reporting threshold changes (although we don't have to report now)
Additional higher threshold requirements to require banks to escrow

There are also a bunch of other changes, including changes on capital levels, call reports, freezes on credit reports, etc.

Also, hope this is the correct spot for this even though it hasn't passed yet.

So, if this passes, if you originate fewer than 500 closed-end mortgage loans for 2 consecutive years, you are no longer a HMDA reporter?

And by "mortgage loans", do we mean secured by a dwelling? Sorry, i haven't worried too much about coverage in the past because we were always well above the requirements, but we might not be if this passes.

I think you would be exempt from the new data points, but maybe not the old ones???? It looks like it would only exempt paragraphs 5 and 6.

The act defines as -

Thanks.....i guess i need a little help figuring out exactly what parts "paragraphs 5 and 6" are referring to.

I have understood it you are exempt from all reporting if fewer than 500. Either way, if it is exempt from all or only the new xdata, it would cut down work. I have been working on our LAR for January and the process has definitely slowed compared to December.

No doubt.

I think it could be a logistical nightmare for the vendors if it's only partly affected...meaning data point changes only.

As far as mortgages, we are so close to that number even though my LAR lines cut down this year...if you consider how many were exempt but were still 'mortgage loan's, I'm just not sure how it would fall out. If they go by hard fact LAR lines, it might be easier to judge.

Although that document just made my eyes hurt, I'm not seeing any wonderful revelations in it. I believe fmissles assessment is right...it's just a cut back to the old reporting points at best.

The it's a "QM" if held in portfolio is not all that "meets the eyes" either, I'd say.

Hard to say RR, I thought it would give Banks a way to make QM loans that can be held in portfolio (which is what we would want), but I didn't dissect it enough to be sure.

As an update, this passed Senate cloture yesterday, which means it can be voted on at anytime now. If passed, it will either go to the House or go to conference where it will be reconciled with any number of House Bills that have already been voted on, on that side.

Well, we currently make QM loans held in portfolio [small creditor, at least] and I guess that's how I was looking at it...I just didn't see any real change there...at least not for us.

I had thought by reading our state magazine and other things that the difference on the portfolio QM front was that any loan kept in portfolio would AUTOMATICALLY be a QM.

That's not how I read it. Seemed it still has to be underwritten properly, [ATR] etc.

If so, (and you may well be right), i don't understand what would be so great for community banks. As you say, we already qualify just about every one we do as a balloon or SC QM.

The best chance of seeing this passed may have gone by...

https://www.housingwire.com/articles/42723-senate-postpones-vote-for-dodd-frank-reform-bill

Looks like it is on to the house...

http://www.icba.org/news/news-details/2018/03/14/icba-thanks-senate-for-passing-s.-2155

http://www.icba.org/news/news-details/20...vote-approaches

http://www.icba.org/docs/default-source/...ry.pdf?sfvrsn=0

Yep. Now to see if the house will take it up as is, move it to conference, or let it sit.

I haven't studied this in-depth, but the bill approved by the Senate merely exempts small reporters (Originating 500 or less closed-end loans and open-end LOCs) from the new data points. Now we will have two sets of rules for data points and reporting – one for large reporters using the 2018 rules and ones for small volume reporters using the previous data points.

There will be lots of questions to answer: When can the small reporter stop collecting the other data points? Do they have to report for 2018 under the current rules? Guess we wait and see when they reconcile the house and senate versions and when President Trump signs it into law (provides an effective date for the changes).

I shot a video blog that summarizes the bill. It's not just HMDA, but there are exemptions for appraisals in rural areas, escrows and QM's for banks <$10B and TRID clarification on construction loans. The blog will be up shortly. Go to our website to view it.

I think we'd be a "small reporter" under this change......things like this are actually sort of annoying....the time to "fix" this is before implementation. Changing it after implementation causes as many problems as it "fixes".

I think how many banks the 'small reporter' exemption is going to relieve will depend on if they mean 500 covered loans BEFORE the 2018 rules kicked in (meaning everything consumer with a house on it) or not. We were under 500 for 2017, but I'm pretty sure the 'all-in' reporting is going to put us over.

Would you basically just count your LAR entries (for either 2017 if defined one way, or 2018 if defined the other)? I think either way, we'd be below 500....i've never had a LAR over about 225, and that includes non-originated....i don't expect this year to be over 500 on my LAR either.

This could end up being a mess and I am interested to see how the dust settles. Questions I will be interested to have answered in time:
- When will the rules be effective? Basically, will small reporters continue with the new rules and then revert at the end of 2018 or will they revert mid-year, meaning a corrected LAR is in order for later this year? We saw how long it took the CFPB to issue the last HMDA changes required from a law (Dodd-Frank).
- Will small reporters revert to pre-2018 rules (unlearning everything they just learned), or will they keep the existing rules but only report for similar fields as to what was added? As I recall, only a small handful of fields didn't have any change at all.
- How will DI come into play?
- Will the purpose hierarchy stay the same or revert?

Etc., Etc., Etc.

While this rollback sounds nice in theory, it could create a sizable amount of additional work before any relief is obtain - especially since lenders and vendors will have most of the bugs worked out by the time any rules become final.

Rather than have two different data systems, one for lenders who have to report all of the data fields and another for "small lenders" who are exempt from reporting the 2018+ additional fields, I wonder if they would add a code to those fields indicating that the data was not reported because the lender is a "small reporter".