Page 24 - Waypoint Bank
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U.S. regulatory relief
Dodd-Frank repeal not likely or particularly desired
Priorities:
• TAILOR Act become law – regulate per business model and risk
profile
• Mortgages held in portfolio since origination be automatically
granted QM and ATR status
• CFPB governance, accountability and Congressional oversight and
appropriations
Repeal the Durbin Amendment
Others include:
• BSA • Overdraft
• Tax reform (including but not • Small dollar lending (preemptive
limited to CUs strike)
• Exam appeal/reform • Fair lending, data on small biz
• Credit Unions and FCS over-reach lending
• Appraisals • Remove “Abusive” standard from
• Data breach UDAAP, Basel III requirements
• Defensive (mortgage interest • SIFI threshold from $50 billion
deduction, bank cross-selling and others
practices, GSE reform • Marijuana
Banking regulation
• Complex regulations, for example: TRID mortgage disclosure form (2
merged into 1) has 1,000 pages of instructions – liability if there is
any deviation.
• Some community banks have stopped making mortgage loans
because of this volume, complexity and cost of compliance. Adds to
consolidation pressure, so fewer competitors.
• Trickle down: requirements for big banks imposed on smaller ones
as “best practices.”