Bankers who haven't delved into the actual text of the proposed new Reg C (who've relied on vendor summaries and-or the Fed's discussion material in the Federal Register for proposal impact) may not be aware of the depth & breadth of the revisions.

For ex: regarding the proposed reporting of HOEPA status: Banks that don't make HOEPA loans now and won't be covered by the proposed HOEPA exansion may not realize that the proposed reporting HOEPA status is not a simple "yes"/"no" (where you could automatically categorize all LAR entries "no"). In fact, it must be an appl-by-appl entry. The proposed Reg C gives these "decision tree" choices:
a. If loan or appl is covered by TILA but not covered by HOEPA/Sec. 32 -- enter Code 0
b. If loan or appl is covered by TILA and by HOEPA -- enter Code 1
c. If loan is not covered by TILA, or is covered by TILA but no APR was required to be disclosed to the applicant, or for any other reason it can't be determined whether the loan or appl is covered by HOEPA -- enter Code 2

Comment deadline is March 9.

Actually, I have been thinking the same thing ever since the proposal came out. All of the summaries and brief commentaries I have read make it sound like it's really not that big of a deal. However, when you actually read the proposal and take a look it the potential impact on your institution and your work load, it's pretty scary. PLEASE BE SURE TO SEND YOUR COMMENTS IN - even if you can't make the March 9 deadline! I think it will be a lot easier to do once we have all worked on finalizing our scrubbing for the March 1 submission.

And to think of the opportunity that APR information will provide for Predatory Lenders - combined with the Lender Name, Census Tract, Race, Sex & Income from the Public LAR - and then merged into a database with geocoded address information, lender name, borrower name, loan amount, and street address available from the County Recorder when a Deed of Trust is recorded...

Voila! A list by race, income level, name & address of people who took Section 32 loans from legitimate lenders that an unscrupulous lender can then TARGET direct marketing to get them to refinance their "high cost" loan........

Oh yes - your tax dollars at work!

That is a truly scary thought -- and an important commenting tool. The proposed changes to Reg C could actually provide a tool for predatory lending. That is not what the drafters had in mind!