It’s never a good idea to “guess” how a new law will be incorporated into a regulation, but I have received quite a few questions regarding how small HMDA reporters will report HMDA data once the CFPB finalizes the changes required by the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018.  Therefore, I want to share my understanding of what I think is going to happen, though you should know full well that this is (mostly) just speculation until changes to Regulation C become final.

On July 5, 2018, three of the regulatory agencies issued statements on how the new regulatory reform law (S. 2155) will affect certain HMDA reporters.  Each statement is substantially similar and gives an overview of how the Economic Growth, Regulatory Relief, and Consumer Protection Act amends the Home Mortgage Disclosures Act.  Each statement was substantially similar and essentially has three parts.

After passing through Congress on Tuesday, President Trump today signed into law S.2155, known as the Economic Growth, Regulatory Relief, and Consumer Protection Act.   This banking reform bill, introduced by Idaho Sen. Mike Crapo in November of 2017, does a number of things to undo the burdens placed on smaller financial institutions by the Dodd-Frank Act. One of those things relates to the new fields that were required under the Home Mortgage Disclosure Act (HMDA) beginning on January 1, 2018.