It is interesting in that it:
>changes what has to be in the CRA public file - just the notice that the LAR is available at the CFPB site;
>expands what will be considered as the HMDA part of the CRA exam (your entire LAR, including the new consumer categories) and
>brings in open end for those who must report (for financial institutions that would not be required to report these transactions under Regulation C, examiners may review the relevant files and consider these loans for CRA performance on a sampling basis under the home mortgage loan category)
>removes the home equity category from the CRA categories (has been code 4) as they will now be covered under 'home mortgage loan"
>changes things for non dwelling secured home improvement loans for those who reported them - if you want them considered for CRA you must gather data and present (if you have a significant portfolio, examiners can require including them)
>conforms some language.
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