Page 24 - December 31 2017 Reporter

HMDA and Company—

Highlights for the Upcoming Year continued

in the near future. These are often referred to as
certain model forms and remove others. Thankfully the
“sunset” provisions because the regulatory sun is
changes to HMDA and ECOA go hand-in-hand, as the
quickly setting on them. Some of the major sunset
purpose of the amendments to ECOA is to facilitate
provisions include: sections 531 (maximum rent)
compliance with HMDA version 2018. Note that all
and 533 (foreclosure) of the Servicemembers Civil
these changes to ECOA come into effect on January
Relief Act (SCRA); the U.S. Department of Housing
1, 2018 with the exception of the amendment that
and Urban Development (HUD) SCRA notice; the
removes the Uniform Residential Loan Application.
National Flood Insurance Program (NFIP); and the
This particular amendment becomes effective on
Federal Home Loan Mortgage Corporation loan limit
January 1, 2022.
of $424,100. These provisions are all set to expire at
The final ECOA rule can be found here: http://files.
the very end of 2017, with the exception of the NFIP.
consumerfinance.gov/f/documents/201709_cfpb_final-
NFIP authorization was set to expire on December
rule_regulation-b.pdf
8, 2017, but received a two-week extension by
It didn’t happen for 2016…It didn’t happen 2017…
Congress (currently set to expire on December 22,
but the time you have anxiously been awaiting…has
2017). As of now, none of the provisions have been
finally arrived! The TIL exemption threshold has been
extended past 2017. So, be sure to keep an eye on
adjusted. The exemption threshold will increase from
these regulations towards the end of the year.
$54,600 to $55,800, effective January 1, 2018.
In conclusion, there are a great many changes in
The rule updating the threshold can be
store for 2018, but if you are prepared, you should
found here: https://www.federalregister.gov/
be able to handle them with ease and confidence.
documents/2017/11/09/2017-24445/truth-in-lending-
For any questions or concerns, feel free to give
regulation-z
us a call at (888) 353-3933, chat with us on the
The regulators are at it again and are making more
website (https://www.compliancealliance.com), or
changes—this time to the CRA. Once again, these
email us at hotline@compliancealliance.com
changes are aimed at helping banks transition to
the new version of HMDA. The new rule updates the
definitions of “home mortgage loan” and “consumer Sarah Sauceda serves as Associate General
loan,” and the public file content requirements to Counsel for Compliance Alliance. She is an Honors
conform HMDA 2018. The amendments also cleanup Program graduate who graduated summa cum
the CRA by removing now obsolete references to the laude from Lamar University in Beaumont, Texas
Neighborhood Stabilization Program. The comments where she received her bachelor’s degree. While
closed on October 20, 2017, and the final rule at Baylor Law School, Sarah heavily studied
becomes effective on January 1, 2018. the financial aspects of the law—focusing her
attention on secured transactions and the Uniform
The updates to the CRA may be found here:
Commercial Code. Before coming to Compliance
https://www.federalreserve.gov/newsevents/
Alliance, she worked at Frost Bank within their
pressreleases/files/bcreg20170913a1.pdf
Credit Administration Department. As an attorney
Finally: When I think of sunsets, I picture beaches,
with Compliance Alliance, Sarah is eager to help
long walks, and OF COURSE regulations that are
members with their compliance and regulatory
up for renewal. (This is normal, right?) This last
questions.
topic concerns the regulations that are set to expire

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December 2017 IllInoIs RepoRteR