HMDA Proposal Released

The CFPB released a HMDA Proposal on July 24, 2014. The current regulation only takes up 5 ½ pages in my FDIC brown books. The appendixes are another 14 pages and the commentary is another 11 ½ pages for a total of 30 pages. The proposal, on the other hand, is 573 pages long! The Summary/Background takes 51 pages alone. The section-by-section analysis is then 392 pages. The proposed regulation is 48 pages and the Commentary is 63 pages. This is another 573 pages of job security. You can find it all here. Happy reading!

Here’s what we expect (as I look into my crystal ball): The comment period ends on October 22, 2014. The CFPB will consider your comments and then issue a final rule in the first quarter of 2015. The final rule will not go into affect until January 2016, in accordance with the Dodd-Frank Act.

We’ll give the proposal a light read and when the final rule is released, we’ll thoroughly research it and give you a full understanding via our newsletter and seminars.

I’ve heard “HMDA” referred to as “How Many Drinks are Allowed”. As we started reading through the proposal, that may make more sense! As always, stay tuned.

David Dickinson

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