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.
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’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.