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DFA Rollback—New, Old and Changed Rules

On May 24, 2018, a new law was signed that will roll back some of the Dodd-Frank requirements for some banks, but not all. There are some new things in this law intended to make mortgage credit more available from community banks, There are some old things that the new law is breathing new life into. There is even a provision that keeps a protection for servicemembers from changing, making it permanent. But throughout the law, there is change.

This all means there are new requirements mixed into some deregulation. What areas are impacted? There’s mortgage credit; access to credit; protections for veterans, consumers and homeowners; rules for holding companies; capital access; and student borrowers.

When are the changes effective? Some are effective now, some will be in 30 days, 60 days, after a regulation is finalized and so some dates are just not known. A key takeaway is that just because a law is now changed, It doesn’t mean the bank should stop its current compliance procedures. Not right away, anyhow.
We will discuss what we do know, what we don’t know and some strategies for moving forward based on the changes. HMDA has changed for many small reporters. If your bank qualifies, does this mean you rollback HMDA to 2017 rules? No! It isn’t that easy. You need guidance from the Bureau first and then you need to decide on your implementation plan. We can’t give you final details on these and other changes, because the regulators need to act first.

This webinar is intended to make you aware of what will change with an emphasis on regulatory compliance matters, and when and how to manage your compliance process going forward. Making changes in the dark can be risky; we will shed light so that you do not get lost on this journey. We’ll cover all of the portions of the EGRRCPA that affect banks so you can start your change management plan.

THIS IS A REPRISE of our webinar, “Dodd-Frank Rollback – What the New Law Means to You” for those who missed the June 27 presentation. The material covered isn’t changed, although we’ll feature any new developments since the earlier presentation.

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