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.
S.2155 is not going to change the gathering of the 2018 demographics information for anyone. That is not part of the relief. As far as collecting "other byzantine/obscure loan details", they are all in the file already. Whether you choose to continue to organize them in preparation for HMDA filing is the only question. You are not gathering any additional information that is not already in a typical mortgage file for the sake of HMDA reporting.
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