All posts by synergy

House Flipping is Back !

Amid saguaro cactuses and yucca plants, Lauren Rosin shows off a house that she’s renovating in Phoenix’s Central Corridor, a pricy neighborhood north of downtown.

“This was actually a courtyard and I blew it out,” she says, pointing to what will now be an extra-large open kitchen with custom cabinets, quartz countertops and chandelier-style lighting. She’ll also upgrade the swimming pool in the backyard.

But Rosin won’t live in the four-bedroom, three-bath midcentury ranch once it’s finished. She and her business partner Brad Pickett are house flippers: Pickett buys the homes, and Rosin leads a crew of contractors to rehab them. They flipped 27 homes last year.

These days, profits are tight, and they face stiff competition.

That’s because a decade after the U.S. housing bubble burst, house flipping is on the rise again. Defined as reselling a house within a year of purchase, flipping is at an 11-year high in the United States and it’s the subject of dozens of TV shows and weekend workshops promising to teach real estate novices how to make a fortune.

New research shows that flippers contributed to the housing crash of the mid-2000s more than economists initially realized. Because some of the same practices from the boom are making a comeback, some market watchers are concerned that the real estate market might once again be nearing a bubble.

But for now, experts say those concerns are overblown, thanks to changes in the mortgage industry and other factors.

The last time this many homes were being flipped was during the housing bubble. Flipping peaked in 2005, when 8.2 percent of all single-family homes sold nationwide were flips, about 344,000 homes, according to Attom Data Solutions, a research firm that collects and analyzes nationwide real estate data.

In areas where the bubble was growing fastest, flip rates were even higher. In Las Vegas and some parts of Florida, the flip rate reached nearly 19 percent. In Phoenix, about 16 percent of homes sold were flips.

A look at the market in Phoenix, considered a bellwether by industry experts, is a good way to see how things have changed or not. More than 8,500 homes — or 8.5 percent — sold in the Phoenix metropolitan area last year were flips, more homes than anywhere else in the country, according to Attom.

Before the crash a decade ago, flippers didn’t need to do much to make money. Financing was easy to get; people with high credit ratings could use no-income, no-asset loans to buy real estate. The housing bubble was inflating so fast, investors could buy, hold — sometimes renting out the properties to make a bit extra, sometimes renting at a loss, sometimes not even bothering to rent — then sell, over and over again.

Then the floor fell out from under the housing market.

Lauren Rosin got into flipping in 2009, during the bust. In Phoenix, the crash was disastrous. Homes on average lost 56 percent of their value. Lenders foreclosed on tens of thousands of families.

To Rosin, the wave of foreclosures meant that there were thousands of houses on the market that needed only a face-lift to net her a tidy profit.

“It was really sad because you’re watching so many friends and family go through losing their homes,” she says. “But I just looked at it as such a great opportunity.”

Ten years into her career flipping houses, Rosin’s operation is much more streamlined and professional. But it’s harder to make money now, she says.

Her profit margins are significantly thinner, typically 10 to 15 percent of the eventual sales price. She has to know exactly which amenities will yield more profit and which to skip, and the fine line between upgrading and going overboard.

New research and data suggest that the practices of house flippers fed the bubble of the early 2000s. Much of the blame for the housing crash has fallen on subprime borrowers and people who bought and lived in homes they couldn’t afford.

But researchers are now coming to understand that a big part of the problem was people with better-than-average credit scores who owned multiple homes — not subprime buyers, but real estate investors, landlords and flippers.

Stefania Albanesi, an economist at the University of Pittsburgh, argues that the rise in mortgage defaults during the housing crash was mostly attributable to real estate investors, including flippers.

During the bubble, about two-thirds of home flips nationwide were financed with loans, according Attom. In places like Phoenix and Florida, that number approached 80 percent.

The problem with that, Albanesi says, is that real estate investors such as flippers are at greater risk of defaulting on their mortgages than normal homeowners.

“If you lose your home that you’re living in, you have to relocate your family, find other housing, and maybe have a longer commute,” Albanesi says. “This is not something that’s there for the investor. Overall, their default probability is much greater.”

Normally, people with above-average credit scores are unlikely to default on their mortgages. But during the crisis, Albanesi’s research shows, it was borrowers with good credit scores who had taken out mortgages on additional properties — mostly investors — who defaulted at historically high rates.

“These borrowers looking to buy their second, third and fourth homes would tend to go to unconventional lenders and would tend to obtain loans through nonstandard products such as adjustable-rate mortgages and so on,” Albanesi says. “These loans are more expensive. They have higher interest rates. And so, other things equal, it’s more likely that these borrowers might default.”

Despite the volatility they can bring to a market, flippers can and do bring value. Many homebuyers don’t have the energy, resources or know-how to renovate a home that needs it. Flippers can help boost the supply of “move-in ready” homes.

“I don’t think there’s anything inherently wrong with flipping itself,” says Steve Swidler, a finance professor at Auburn University. “In fact, flipping has probably given life to the housing markets that were most hurt back in the financial crisis itself.”

Now that the real estate market has stabilized, flippers can’t ride the bubble or scoop up foreclosed properties on the cheap. They have to add real value to turn a reliable profit.

At the height of the bubble in Phoenix, the typical flipped home was originally constructed in the mid-1990s, according to Attom. In other words, people were flipping properties that were only about 10 years old.

Now, the average flipped property is typically about 30 years old.

“They’re older homes, which inherently are going to require more work,” says Daren Blomquist, senior vice president for communications at Attom. “They’re going to actually have to improve the conditions of these homes, which I think is healthy for the housing market. Flippers can step in and actually provide inventory of homes that are somewhat ‘like new’ if they do a good job.”

In areas that didn’t experience the housing bubble as intensely as places like Phoenix, Las Vegas or Florida, flipping rates have stayed more stable, growing slowly over time instead of swinging wildly from boom to bust.

But as flip rates in cities like Virginia Beach, Va., Baltimore and Birmingham, Ala., near 10 percent, some wonder if there is cause for concern.

Real estate experts in Phoenix, where these risk factors are ahead of national levels, say there’s no reason to sound the alarm yet.

During the housing boom, prices were rising so quickly that inexperienced real estate investors could turn a profit despite their lack of expertise, says Mark Stapp, who teaches real estate development at Arizona State University.

“Today, you can’t. It’s harder,” he says. He points to financing and commercial lenders. During the bubble in Phoenix, more than 75 percent of flips were financed with loans. Now, flippers in the area acquire about half their homes with financing, half with cash.

“Commercial lenders have been very disciplined,” Stapp says. “The loan-to-value, loan-to-cost, those kind of metrics, they’re keeping very low and tight control over. The issues we had previously with abuse through manipulating appraisals, that isn’t really happening.”

Simply put, Stapp says, though some of those inexperienced flippers are back, they’re still too small a portion of the market to worry about.

“I think it’s such a small number,” he says. “I don’t think it’s to the point where it so dramatically affects the market that the market gets hurt by it.”

 

 

Inside Scoop on Your Mortgage Lending Competition – FINTECH

A shrinking inventory of affordable housing and rising mortgage rates are making the real estate market even more competitive for homeowners. Those looking for an edge may want to consider getting a loan from a financial technology startup, otherwise known as a fintech.

A new report from the Federal Reserve Bank of New York and New York University issued by the National Bureau of Economic Research found that technology-driven lenders have created efficiencies in the home lending business that give them an edge over traditional lenders. These fintechs are able to process loans quicker, can better handle movements in demand and have fewer loans that end up defaulting. They are also gaining on their traditional brethren, with the study finding that fintech lenders’ market share jumped to 8% in 2016 from 2% in 2010. In 2010, the fintechs originated $34 billion in mortgages. That stood at $161 billion as of the end of 2016. A lot of the growth came from Federal Housing Administration loans.

[Check out Investopedia’s mortgage calculator to find out how much home you can afford.]

In terms of their ability to process mortgage loans, the research revealed that fintechs are doing so about 20% quicker than traditional lenders. “Faster processing does not come at the cost of higher defaults. Fintech lenders adjust supply more elastically than other lenders in response to exogenous mortgage demand shocks, thereby alleviating capacity constraints associated with traditional mortgage lending,” wrote the New York Fed and New York University in the report. “In areas with more fintech lending, borrowers refinance more, especially when it is in their interest to do so. We find no evidence that fintech lenders target marginal borrowers. Our results suggest that technological innovation has improved the efficiency of financial intermediation in the U.S. mortgage market.”

The researchers found that around 25% of mortgages issued by fintechs defaulted, which is lower than the industry average. That derails the argument that fintechs engage in lax screening of borrowers and actually implies they are attracting and providing home loans to borrowers who are less risky.

As for who is taking out a mortgage with a fintech over a traditional lender, the study found that the borrowers tend to be from more educated populations and are older, which may be surprising but could be because they are more familiar with the process of getting a mortgage and thus require less hand-holding. What’s more, the study found no evidence that fintechs are going after marginal borrowers and reported that there is no digital divide in mortgage lending.

“Recent technological innovations are improving the efficiency of the U.S. mortgage market. We find that fintech lenders process mortgages more quickly without increasing loan risk, respond more elastically to demand shocks, and increase the propensity to refinance, especially among borrowers that are likely to benefit from it,” wrote the researchers.

Source: https://www.investopedia.com/news/fintechs-give-mortgage-borrowers-edge/

Maybe You Should Contribute to Your Borrower’s Closing Costs

While it’s not quite the same as the down payment assistance that the government-sponsored enterprises used to allow, lenders now have a new way to help borrowers buy a home – closing cost assistance.

Fannie Mae announced this week that it will now allow lenders to contribute to borrowers’ closing costs, as long as the money is a gift and is not used towards a borrower’s down payment.

Over the last few years, Freddie Mac on a larger scale, and Fannie Mae on a smaller scale, allowed lenders to gift money to borrowers that could be used on their down payment on a 3% down mortgage.

Under the programs, lenders would “grant” 2% of the down payment to the borrower. Add that to the borrower’s 1% contribution, and you would have the 3% needed to qualify for the Fannie and Freddie programs.

These programs fell out of favor after some lenders began rolling the “grants” back into the loans themselves in the form of premium pricing, wherein the lender would charge a higher interest rate in exchange for the down payment assistance.

That raised some flags with the Federal Housing Finance Agency, which eventually led to Freddie ending the program last summer.

At the time, the FHFA told HousingWire that it was monitoring the situation and had some concerns about the risks associated with charging certain borrowers higher interest rates in exchange for down payment assistance.

The FHFA told HousingWire that it was concerned that those borrowers might end up paying more over the life of the mortgage than what the lender provided in assistance.

So, the down payment assistance programs ended, at least in terms of the 2% coming directly from the lender and needing to be repaid.

Recently, HousingWire exclusively reported that United Wholesale Mortgage would be ending its 1% down program, in which the lender was gifting the entire 2% of the down payment to the borrower and not pricing the gift into the loan.

But now, lenders who sell their loans to Fannie Mae can begin offering closing cost assistance to borrowers, under certain circumstances.

According to an announcement sent this week by Fannie Mae to lenders, the money must be in the form of a gift and cannot be subject to any sort of repayment requirement.

Additionally, the money must not be used to fund any portion of the borrower’s down payment. The money can be used for closing costs and fees only.

Fannie Mae also said that there is no limit on the amount a lender can give to a borrower, just as long as it does not exceed the total closing cost amount.

“We’re making it easier for borrowers to purchase a home by allowing lenders to fund closing costs and prepaid fees,” Fannie Mae Chief Credit Officer for Single-Family Carlos Perez said in a letter to lenders.

“While there is no limit to the amount of the lender-sourced contributions, the funds cannot be used toward a down payment, cannot exceed the total closing costs, and should not be subject to any form of repayment agreement,” Perez added.

Additionally, Fannie Mae notes in its lender bulletin that the closing cost assistance must come directly from the lender and cannot be passed to the lender from a third party.

And now, for the fine print, taken from Fannie’s lender bulletin:

The amount of the lender contribution should not exceed the amount of borrower-paid closing costs and prepaid fees. Otherwise, the amount of the contribution is not limited except when the lender is an interested party to a purchase transaction as defined in B3-4.1-02, Interested Party Contributions, and in that case, the interested party contribution (IPC) policy applies. Any excess lender credit required to be returned to the borrower in accordance with applicable regulatory requirements is considered an overpayment of fees and charges, and may be applied as a principal curtailment or returned in cash to the borrower.

A spokesperson for Fannie Mae told HousingWire that the program was previously available on a limited trial basis to certain lenders. But now, the GSE is making the option available to all lenders.

According to Fannie Mae, lenders can begin contributing to borrowers’ closing costs under those specified conditions immediately. The change goes into effect now.

Source:https://www.housingwire.com/articles/43022-fannie-mae-now-allowing-lenders-to-contribute-to-borrower-closing-costs

What You Need to Know About TRID 2.0 Coming in October 2018

The amendments to the Know Before You Owe/TILA-RESPA Integrated Disclosure rule issued last month were a long time coming, but overall were worth the wait.

TRID 2.0 addressed many of the pain points that our industry has struggled with over the past two years. The new rule becomes effective 60 days after it is published in the Federal Register, but compliance isn’t mandatory until October 1, 2018.

From a Consumer Financial Protection Bureau-watcher’s perspective, it appears that the Bureau heard and responded to the mortgage industry’s concerns, but there are still a handful of large issues that remain. While the CFPB stopped short of immediately closing the “black hole” that generally prevents lenders from re-setting fee tolerances when a Closing Disclosure has been issued prematurely, it did issue a new proposed amendment to address this problem. Concerned about unintended consequences, the CFPB is asking for comments on the proposed “black hole” fix.

Having said that, industry reaction to TRID 2.0 was mixed. Some lenders expressed disappointment that additional cure provisions for violations were not included, while secondary market investors were pleased that TRID 2.0 addressed many ambiguities in the original rule that could potentially create assignee liability.

Probably the strongest negative reaction came from the title industry. Michelle Korsmo, the American Land Title Association CEO, opined in a press release that the rule still results in consumers not receiving accurate information about title insurance costs. She stated, “While the CFPB’s disclosures have helped homebuyers better understand their mortgage costs, consumers would value their disclosures more if the CFPB showed the accurate costs of title insurance instead of the incremental costs.”

Here are some of the more significant changes contained in the 560-page TRID 2.0 document:

–Clarification of “no tolerance fees.” The new rule makes it clear certain products and services, such as property insurance, impound and escrow amounts, are still excluded from zero and 10 percent tolerances, even if they are paid to an affiliate of the lender. The only caveat is that the original estimates can’t be unreasonably low. Also, the preamble to the amended rule reaffirms that “typographical errors regarding a settlement service…do not subject the charges for such a service to the zero percent tolerance category…” in most instances.

–Construction loan disclosures. The Bureau made a number of additions to Appendix D, and clarified how construction loan inspection and phase-specific fees should be disclosed before and after the project is completed. If the fees are collected after the project is completed, they must now be disclosed in an addendum to both the Loan Estimate and the CD. Additional clarifications were also made regarding how construction costs, existing lien payoffs and unsecured debt payoffs are disclosed.

–Written List of Providers. The CFPB said that changes could be made to Form H-27 without losing safe harbor protections. The amended rule also clarifies when a service is considered “shoppable.” In addition, the Bureau said that a WLP may exclude a list of fee estimates not required by the lender, such as title search, notary, and fees for other administrative services.

–Re-disclosures after Rate Lock. A lender must issue a revised LE after the interest rate has been initially locked if no CD has been issued. Once a CD has been issued, the lender must issue a revised CD if the rate lock makes the CD inaccurate.

–Cost reductions after initial LE. The Bureau clarified that cost reductions of certain items don’t automatically reset tolerances. Tolerance determinations are based on comparisons between “the charge paid by or imposed on the consumer” versus “the amount originally disclosed” or a revised estimate.

Based on our discussions with clients, the overall reaction to these changes seemed to be positive. However, many clients are still working their way through the documents and probably won’t start implementing these changes in their systems and workflows until after the deadline for the GSE’s Uniform Closing Dataset compliance has passed.

(Views expressed in this article do not necessarily reflect policy of the Mortgage Bankers Association, nor do they connote an MBA endorsement of a specific company, product or service. MBA Insights welcomes your submissions. Inquiries can be sent to Mike Sorohan, editor, at msorohan@mba.org; or Michael Tucker, editorial manager, at mtucker@mba.org.)

Source: https://www.mba.org/publications/insights/archive/mba-insights-archive/2016/trid-20-more-clarity-and-a-potential-fix-for-the-black-hole

About to be Audited ? E-Exams are Here !

By Sharif Mahdavian

In the wake of the last decade’s mortgage crisis, state and federal regulators looked to technology to help address the need for more comprehensive mortgage loan reviews. Determining whether an individual loan or a lender’s total production complied with applicable laws and regulations was no small feat. Examiners had to sift through piles of documents to extract data points relevant to various rules. Without technology, reviewing 100 percent of a lender’s production was clearly impractical.

The creation of the National Cooperative Agreement for Mortgage Supervision a decade ago was a major step in improving cooperation and coordination among state regulators. Model examination guidelines developed by the cooperative allowed the use of automated technology for examiners to enable comprehensive loan audits, rather than sample-based manual reviews.

Automated Compliance Tools Regulators Are Using

The electronic examination (e-Exam) process is now being used for both single and multi-jurisdictional examinations. Today, the vast majority of jurisdictions have utilized the e-Exam process.

This platform and the e-Exam format provides users with comprehensive reporting far beyond what is available through manual processes. In addition to federal and state high-cost tests, tests for TRID and QM status can be returned virtually instantaneously. Tests are tailored not only to specific lending guidelines, such as those for the government sponsored entities (GSEs), but also for originator license type.

The Compliance Evolution

Recent announcements from the Consumer Financial Protection Bureau (CFPB) suggest “regulation by enforcement” is going away in favor of a more collaborative environment in which there will be formal rulemaking on which financial institutions can rely. And it acknowledges the current state of play: lenders do not want to violate applicable rules, and regulators want to foster compliant lending.

For regulators, the results of e-Exams can uncover systematic difficulties that lenders face and provide guidance as to which regulations need greater clarification. The existing (and hopefully soon to be corrected) TRID “black hole” is a prime example. In the current rule, well-intentioned lenders cannot amend closing disclosures when acting in good faith if the initial closing disclosure was issued too early. Last August, the CFPB proposed an amendment that will allow creditors to reset tolerances by providing a closing disclosure, including any corrected disclosures, within three business days of receiving information sufficient to establish that a reason for revision applies. The CFPB has sought extensive comments on the proposed fix, but, at the time of this writing, a finalized amendment has yet to be issued.

Another prime example is per diem interest regulations. In California, four of the top 10 non-bank lenders were fined more than $13 million in the last year and a half for violating the state’s per diem interest rule. Today, the automated compliance tool can not only allow regulators to test for such violations, but also enables lenders to test for permissible per diem limits and correct any variances before they become violations.

In addition, automated compliance testing with advanced tools can provide information not only on what limits have been exceeded, but what specific fees, disclosures, or delivery timing sequencing have caused a potential violation. This testing translates into lenders being able to make complaint restitution when appropriate and alter processes to avoid future problems.

 

Source: http://www.mortgagecompliancemagazine.com/technology/past-present-future-e-exams/

How to Tighten Timelines and Streamline the Mortgage Origination Process

Thirty years ago, mortgage origination was a simple process. An application was taken at the local savings and loan branch, documents were prepared within 48 hours, sent to a title company with a note to close, and then the entire deal was sealed within days with a congratulatory handshake to the happy new homeowner.

What once took less than a week to complete now takes approximately 50 days—with plenty of hoops for lenders to jump through. In today’s environment, lenders are responsible for complex data management and hundreds of active compliance regulations, with steep fines if they get it wrong.

To succeed in an environment of increasingly narrow margins, broad competition, and ever-more complex regulation, lenders must take a methodical approach to loan origination, adding dynamic, optimized workflow technology. This need for compliance, data, technology, and management to exist within the same ecosystem is greater than ever. The good news is that, in an increasingly digital world, achieving such operational control is becoming more manageable. Best-in-class solutions are crossbred compliance management systems (CMSs) built by software engineers and maintained by a team of experts well versed in financial law and regulatory compliance knowledge.

For an industry that has been slow to adapt, this emergence of sustainable, smart, and reliable digital compliance ecosystems fosters an environment that can effectively improve the way the industry manages regulatory changes. These expertise-fueled solutions empower financial institutions to respond with agility to the ever-growing regulatory landscape. Alleviating the burden of managing the overwhelming compliance infrastructure frees lenders to focus on profitability and look to the future, instead of over their shoulders.

The key lies in finding the right tool that combines most, if not all, compliance management and delivery needs into a single CMS. As regulation continues to impact the financial services industry with a near-constant cycle of updates, new regulations, and processes, the pressure compresses down to the finance and compliance professionals. In addition to existing job responsibilities, the mortgage banking industry at large balances a myriad of siloed tools that slow them down and lead to decreased productivity across the board.

Today’s comprehensive CMS solutions, however, are designed to keep institutions safe, cost-effective, and on pace with regulators in one seamless platform.

 

Source: http://www.themreport.com/daily-dose/03-12-2018/navigating-mortgage-ecosystem

CFPB Launches 2018 HMDA LAR Formatting Tool

The LAR Formatting Tool is intended to help financial institutions, typically those with small volumes of covered loans and applications, to create an electronic file that can be submitted to the HMDA Platform.

Filers will not need to use the LAR Formatting Tool if they are able to format their HMDA data into a pipe delimited text file by using, for example, vendor HMDA software, the financial institution’s current Loan Origination Software (LOS), or applications such as Microsoft® Access® or Excel® that may be used for data entry and formatting.

Please review Section 2 of the HMDA Tools Instructions guide prior to downloading the tool.

Download the HMDA 2017 LAR Formatting Tool

Download the HMDA 2018 LAR Formatting Tool

Source : https://www.consumerfinance.gov/data-research/hmda/lar-formatting-tool

FFIEC Issues 2018 Guide to HMDA Reporting

A Guide to HMDA Reporting: Getting It Right! will assist you in complying with the Home Mortgage Disclosure Act (HMDA) as implemented by the Consumer Financial Protection Bureau’s Regulation C, 12 CFR Part 1003 (Regulation C). The purpose of this Guide is to provide an easy-to-use summary of certain key requirements. This Guide does not provide detailed information about the HMDA submission process, or file, data, and edit specifications. Information about those topics may be found on the FFIEC’s Resources for HMDA Filers website, available at www.consumerfinance.gov/data-research/hmda/for-filers and www.ffiec.gov/hmda/. The Foreword and Summary of Requirements sections of the Guide were developed by the Federal Financial Institutions Examination Council (FFIEC) — the Board of Governors of the Federal Reserve System (Board), the CFPB the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the State Liaison Committee (SLC) — and the U.S. Department of Housing and Urban Development (HUD). The appendices include, in addition to Regulation C and its Official Interpretations, certain HMDA compliance materials developed and issued exclusively by the CFPB and not by the FFIEC or its other member agencies. Financial institutions may wish to consult and rely upon additional compliance resources that their Federal supervisory agencies may offer. Contact information for each agency is available in Appendix H. This edition of the Guide incorporates the amendments made to HMDA in the DoddFrank Act. 1 The Dodd-Frank Act amended HMDA, transferring rulewriting authority to the Bureau and expanding the scope of information that must be collected, reported, and disclosed under HMDA, among other changes. In October 2015, the Bureau issued the 2015 HMDA Final Rule implementing the Dodd-Frank Act amendments to

Regulation C. 2 On August 24, 2017, the Bureau issued a final rule further amending Regulation C to make technical corrections and to clarify and amend certain requirements adopted by the 2015 HMDA Final Rule.3 The 2015 HMDA Final Rule modified the types of institutions and transactions subject to Regulation C, the types of data that institutions are required to collect, and the processes for reporting and disclosing the required data.4 The Summary of Requirements reviews HMDA’s purposes and data collection, reporting, and disclosure requirements. It provides a high level summary of:  The institutions covered by Regulation C.  The transactions covered by Regulation C.  The information that covered institutions are required to collect, record, and report.  The requirements for reporting and disclosing data. This Guide is not a substitute for HMDA or Regulation C. Regulation C and its official interpretations (also known as the commentary) are the definitive sources of information regarding their requirements. Regulation C is available in Appendix F and G of this Guide and at www.consumerfinance.gov/regulatory-implementation/hmda/.

Additionally, this Guide is not a substitute for the requirements for filing the reportable data. The Filing Instructions Guide is the definitive source for information regarding the filing requirements and is available at www.consumerfinance.gov/dataresearch/hmda/for-filers. 5 Feedback The FFIEC welcomes suggestions for changes or additions that might make this Guide more helpful. Write to: FFIEC, 3501 Fairfax Drive Room B-7081a Arlington, VA 22226 Send an e-mail to: GettingItRightGuide@cfpb.gov Questions If, after reviewing the resources in this Guide, you have a question regarding a specific provision of the regulation, or have questions about how to file HMDA data, please email HMDAHELP@cfpb.gov with your specific question, identifying the filing year you are referencing, and, when applicable, the section(s) of the regulation related to your question. You can also submit the inquiry online using the form available at

hmdahelp.consumerfinance.gov. The information you provide will permit the Consumer Financial Protection Bureau to process your request or inquiry. You may also contact your appropriate Federal HMDA reporting agency (see Appendix H to this Guide.)

Source: https://www.ffiec.gov/hmda/pdf/2018guide.pdf

Are Banking Regulations About to Ease ?

A Senate bill with bipartisan support would significantly ease the regulatory burden placed on banks by Dodd-Frank legislation passed during the Obama administration following the 2008 financial crisis, The Washington Post reports.

The bill, which is favored by Republicans but also has more than a dozen Democratic supporters, aims to provide relief to midsize and regional banks. The bill’s supporters say Dodd-Frank unfairly lumps smaller banks in with the largest financial institutions, making it difficult or impossible for them to survive.

What is Dodd-Frank?

The Dodd-Frank Wall Street Reform and Consumer Protection Act, named after former Sen. Christopher Dodd (D-Conn.) and Rep. Barney Frank (D-Mass.), serves two purposes: Regulate the financial industry to prevent major collapses like the one in 2008, and protect consumers from abusive lending practices.

The 2008 financial crisis occurred largely due to risky investments that started at the local level and got sold up the chain.

Local mortgage brokers offered subprime home loans to consumers at high-risk of default, and those loans were sold to larger firms and subsequently bundled in bonds and sold worldwide.

When large numbers of homeowners defaulted, the bonds, and other assets based on the bonds, collapsed.

Dodd-Frank made it more difficult for banks to use these unstable financial products by increasing supervision and making mortgage lending rules more strict, created the Consumer Financial Protection Bureau to protect borrowers, and created a system for the orderly dissolution of a large failed financial company.

Why would that be rolled back?

Some feel that Dodd-Frank was an overreaction to the financial crisis, and that the resulting regulations have crippled small- and mid-size financial institutions, punishing them for the mistakes of Wall Street.

Sen. Jon Tester (D-Mont.) said the regulations have caused banks in his state to go out of business, and said this bill helps out midsize and regional banks without letting Wall Street off the hook.

“The Main Street banks, community banks and credit unions didn’t create the crisis in 2008, and they were getting heavily regulated,” Tester said according to The Washington Post. “There’s not one thing in this bill that gives Wall Street a break.”

What would the bill do?

The bill would exempt financial companies with assets between $50 billion and $250 billion from the Federal Reserve scrutiny mandated by Dodd-Frank. Only banks with more than $250 billion in assets, of which there are fewer than 10, would receive the highest level of regulatory scrutiny.

What’s the argument against this bill?

Critics say that Dodd-Frank has been successful in preventing financial crises, and that even partial repeals of the law carelessly increase the risk that another collapse could take place.

“On the 10th anniversary of an enormous financial crash, Congress should not be passing laws to roll back regulations on Wall Street banks,” Sen. Elizabeth Warren (D. Mass.) said. “The bill permits about 25 of the 40 largest banks in America to escape heightened scrutiny and to be regulated as if they were tiny little community banks that could have no impact on the economy.”

What are the chances of the bill passing?

The bill has a good chance of getting the necessary 60 votes in the Senate because of the significant Democratic support.

The House has passed a bill already that would roll back Dodd-Frank even further. But, Senate Democrats have expressed resistance to significant changes to the Senate bill, which could make reconciliation with the House bill more difficult.

Web Statistics