Thread Starter: Anonymous
Title: Re: S.2155 - passed Senate with 100 amendments but...
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OP here: This is why it won't be difficult. The New CFPB (whatever you call it now), I predict, will say:
1. Use the new 2018 LAR tool
2. But hit delete on all the data that is covered by the exemption that became effective 5/23 or 5/24/18
3. They will tell us there will be no penalties or ECOA violations for over-collecting or over-reporting for any time in 2018. They'll give us time to absorb this new law and make changes in June, July, August, etc. If you file something you could have deleted, they won't penalize you. 2018 is a diagnostic year.
I think you'll be told that you can just delete what extra data you collected in 2018, even retroactive to 1/1/18, even thought the law passed in May. Your 26-column LAR will be filed on a 109-column reporting tool. You can very, very easily wipe out all this data if you move it to excel, delete your data from certain columns, and upload it to CFPB. Easy peesy. A 1-hour fix done in Feb. 2019. Not a problem.
I predict also that they'll release a 26-column tool in either 2018 or 2019, so that you can switch to that soon as you can. And they'll give you as much time as you need, without penalizing you for using the 109-column LAR when you didn't have to.
These changes are very good for banks. This is a major victory for common sense regulation of smaller financial institutions, a very historic day. Let's make sure we don't waste the opportunity to celebrate.
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