REGULATORY RELIEF ON THE WAY

The House of Representatives has passed the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). The House version is an identical copy of the Senate bill (S 2155) which now goes to the President for signature. The bill covers a lot of territory. The compliance provisions of EGRRCPA:

  • Provide partial relief from the new HMDA disclosures added by the Dodd-Frank Act for small volume originators (fewer than 500 closed end/500 open-end loans for each of previous two years) except for institutions with “Needs to improve” or “Substantial non-compliance” CRA ratings;
  • Provide TILA escrow exception for banks with under $10 billion in assets originating 1000 or fewer first lien principal dwelling loans;
  • Provide qualified mortgage status for most mortgages held in portfolio for banks with less than $10 billion in assets;
  • Provides relief from appraisal requirements for smaller mortgages;
  • Provides for longer exam cycles for community banks; and
  • Reinstates permanently the Protecting Tenants at Foreclosure Act, which expired 12/31/14

Other bills still lingering in one house or the other will likely provide additional regulatory relief

The effective dates for all sections of the law are not clear. Some regulations will have to be written. Effective dates are established for:

  • Section 106 Eliminating Barriers to Jobs for Loan Originators is effective 18 months after the date of enactment.
  • Section 208 Application of the Expedited Funds Availability Act is effective 30 days after the date of enactment.
  • Section 209 Small Public Housing Agencies is effective 60 days after the date of enactment.
  • Section 301 Protecting Consumers’ Credit is effective on the date that is 120 days after the date of enactment
  • Section 302 Protecting Veterans’ Credit is effective on the date that is 1 year after the date of enactment
  • Section Restoration of the Protecting Tenants at Foreclosure Act of 2009 is effective on the date that is 30 days after the date of enactment
  • For Section 306 Family Self-Sufficiency Program not later than 360 days after the date of enactment of this Act, the Secretary of Housing and Urban Development shall issue regulations to implement this section and any amendments made by this section, and this section and any amendments made by this section shall take effect upon such issuance.
  • Section 309 Protecting Veterans From Predatory Lending is effective on the date of enactment.
  • Section 310 Credit Score Competition is effective on the date that is 180 days after the date of enactment.
  • For Section 401 Enhanced Supervision and Prudential Standards for Certain Bank Holding Companies except as provided in paragraph (2), the amendments made by this section shall take effect on the date that is 18 months after the date of enactment of this Act.

(2) Notwithstanding paragraph (1), the amendments made by this section shall take effect on the date of enactment of this Act with respect to any bank holding company with total consolidated assets of less than $100,000,000,000.

  • For Section 506 U.S. Territories Investor Protection except as provided in paragraph (2), the amendment made by subsection (a) shall take effect on the date of enactment of this Act.

(2) With respect to a company that is exempt under section 6(a)(1) of the Investment Company Act of 1940 (15 U.S.C. 80a–6(a)(1)) on the day before the date of enactment of this Act, the amendment made by subsection (a) shall take effect on the date that is 3 years after the date of enactment of this Act.

A copy of the 194-page bill is available at: https://www.congress.gov/115/bills/s2155/BILLS-115s2155es.pdf

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