Thread Starter: Anonymous
Title: Re: S.2155 - passed Senate with 100 amendments but...
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I think I am unclear on what S.2155 actually does. Does it:
a) Provide exemption for some (or all?) of the new HMDA items specified by Dodd-Frank?
b) Or undo only the discretionary data points invented by CFPB?
c) Or both of the above?
d) Or create a 3rd list, and exempt only those?
Randy’s response indicates that we would be exempt from numerous items that were specifically spelled out in Dodd-Frank, that is, not the discretionary items dreamed up by CFPB, but rather, items from the actual text of Dodd-Frank, including:
1. Points & Fees
2. Difference between APR and benchmark rate
3. Prepayment penalty
4. Property Value
5. Intro rate period
6. Whether terms include non-amortizing features
7. Term in months
8. Channel
9. NMLS of originator
10. Universal loan ID.
11. Parcel Number
12. Credit Score
My understanding was Dodd-Frank also required reporting of:
13. Applicant Age, and
14. Postal Address,
…but I could be mistaken. Old HMDA was 26 columns of data. With Dodd-Frank changes only (and without any added discretionary items), we’d be looking at some 39 data points, representing, I believe, 44 data columns total (since some items must be reported for each of two applicants), if CFPB had only added the data points specified in Dodd-Frank.
However, CFPB used the phrase “such other information as the Bureau may require†to change the LAR from the 39 to 44 columns it would have been, up to the full 109 columns it is today. Following are the data points that I believe CFPB initially added under its own discretion, and these would be, I thought, also subject to exemption via S. 2155 for smaller institutions:
15. All the new ethnicity, race, and sex choices, as well as whether they were collected visually (reducing GMI back to 6 columns of data per borrower, instead of this year’s 18 columns per borrower)
16. The new choices in Loan Purpose (elimination of having to distinguish between cash out refi vs. refi with no cash out)
17. Construction Method – though this is really just another way of saying property type
18. Change to occupancy type (from “owner occupied as principal residence vs. NOT owner occupied as a principal residence" to the more complex “principal vs. secondary vs. investment†which clouds the question of whether the loan is consumer or commercial when “investment†is chosen)
19. Making county code 5 digits, census tract 11 digits – though this probably won’t change since FFIEC is transitioning this to CFPB - and maybe this is what CFPB is using as "parcel number" because I don't see "parcel number" anywhere in the 2018 LAR filing tool.
20. Credit Scoring Model code & free-form – though I suspect we’ll have to keep this, otherwise the Credit Score is rendered meaningless, isn't it?
21. Mandatory reporting of reasons for denial (this could go back to optional)
22. Total Loan Costs
23. Origination Charges
24. Discount Points
25. Lender Credits
26. Interest Rate
27. Debt-to-Income Ratio
28. Combined Loan to Value
29. Balloon Payment
30. Interest-only payments
31. Manufactured Home Property Type
32. Manufactured Home Land Property Interest
33. Total Units
34. Multifamily Affordable Units
35. Initially Payable to Institution
36. Automated Underwriting results for each borrower (eliminates 12 columns)
37. Reverse Mortgage yes/no
38. Open-end line of credit yes/no
39. Business or commercial purpose
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