And as a further comment on HMDA, I think that the Income reporting should be changed to codes much like CRA Revenue Codes.
I think the Income levels should be broken down into 3 strata - an example would be Code 1 = 0 to 49 thousand; Code 2 = 50 to 99 thousand, and Code 3 = 100 thousand and above.
IMHO, this would do two things: 1) protect the income information of individual borrowers while still giving a broad picture of Low, Middle and Upper incomes; and 2) Lesson the risk for criticism when an examiner re-underwrites a file and determines that you should have reported 112 thousand in income instead of 111.
A further comment on HOEPA, we don't need NEW laws, we need better, and more even, enforcement of existing laws. Many predatory lenders would only be examined by state agencies. What if the banking agencies offer to provide exam teams (with the cost compensated by the state) to review lenders that don't come under a Bank exam? What if individual county or state D.A.'s office require to be notified of all foreclosures on 1-4 family dwellings? The D.A. could send a notice to the owner asking if they would like a local legal help clinic to review their loan for any predatory or illegal terms?