Thread Starter: Anonymous
Title: Re: S.2155 - passed Senate with 100 amendments but...
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OP here: I don't work for a regulator, but for a smallish bank that will benefit tremendously by the rollback of this poorly-thought-out 109-column LAR garbage.
ICBA's summary shows that certain provisions of S. 2155 require rulemaking, while others do not. The HMDA provision does not require rulemaking as is effective immediately.
This is a unique thing during my few (15 or so) years in banking; I can't recall a law that didn't require rulemaking, so, yeah, the industry is confused...what do we do? How do we comply, with no rulemaking? It's crazy. But it's still a joyous occasion.
What I'm hoping to see is an announcement to be made very, very soon (this week would awesome) by CFPB/BCFP or whatever they call it now, telling us it's effective on X date and how to proceed: whether that means a new LAR tool, a homemade excel LAR, emailing an encrypted .dat file like we used to, or whatever - even using the 109-column LAR would work. Bankers just need the BCFP to step forward and tell us, immediately, what we are supposed to be doing.
In my state, every banker I know is still collecting year 2018 demographics and other byzantine/obscure loan details that we already know we will not have to report. We are wasting a ton of time complying with a law that Congress rendered obsolete, effective almost a month ago now.
CFPB are you listening? Help!
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