Now I know that everyone is real excited about the Senate bill S. 2155 that is gaining some steam in Washington right now. For those of you that have been living under a rock, or possibly on spring break, S. 2155 is proposed legislation that would provide regulatory relief to thousands of credit unions. This bill does have some goodies, and my personal favorite is the relief it would provide to HMDA providers. If enacted, this bill would rescind the additional data points required under HMDA for institutions that originate fewer than 500 closed-end and/or 500 open-end loans. Show of hands, how many of you would love if that came to fruition?
But all of this excitement comes with a word of caution. Do not count your chickens before they hatch and assume that this thing will make it to the finish line. We are talking about Washington D.C. here folks. Even if it does get to the President’s desk, the bill may not look like it did when it first came out of committee.
The moral of my story is that you need to continue to prepare for the upcoming year as if this bill didn’t even exist, because as of right now it doesn’t. Putting off your preparation in the hopes that this bill gets passed could put you in a very uncomfortable situation at the end of the year. So my recommendation to you is keeping fighting the good fight from an advocacy perspective, but as most compliance folks do, plan for the worst (or at least the same).