IMA Prime Times e-Newsletter: November 2017 Iowa Mortgage Association

November 2017


President's Message

Association Updates
Industry News


Season turns to fall; government turns toward tax reform
The days are getting colder and the leaves are changing, making for beautiful scenery everywhere you look; it is fall in the Midwest. Please take some time to think about what you are thankful for this year.  I am thankful for the sound of combines in the fields bringing in what will hopefully be a bountiful harvest, the sight of leaves changing, the feel of the crisp air when I walk out of the house in the mornings and the smell of that final mowing of the grass before everything goes dormant for another season.  

Right now, in Washington, D.C., the focus is on Tax Reform: The Tax Cuts and Jobs Act. On Nov. 6, the Mortgage Bankers Association sent a letter to the House tax-writing committee with their concerns regarding the impact to housing and real estate markets. Negotiations on both sides of the aisle change the landscape quite a bit in a small amount of time, but as of Nov. 7, here are some tax bill takeaways:   

Individual rates are collapsed from seven tax rate brackets into five:
  • Zero: Up to $12,000 (single) or $24,000 (joint).
  • 12%: $12,000-$45,000 (single), $24000-$90,000 (joint).
  • 25%: $45,000-$200,000 (single), $90,000-$260,000 (joint).
  • 35%: $200,000-$500,000 (single), $260,000-$1 million (joint).
  • 39.6%: Above $500,000 (single), $1 million (joint).
  • Eliminates personal exemption. 
  • Itemized deduction limits repealed. Current $261,500 for single and $313,000 for joint.
  • The mortgage interest deduction is reduced to interest on debt up to $500,000 (down from $1 million). Would only be allowed for principal residences (current can be used for vacation homes) and cannot be used for home equity loans. 
  • SALT deduction (state and local property taxes) are capped at $10,000. Eliminates state and local income or sales tax deduction.
  • Capital gain on sale of home – keeps $250,000 (single) and $500,000 (joint) exclusion for gain on the sale of a principle resident. Extends the holding period for use as principle residence to five out of previous eight years from two out of previous five years. Beings phase out at $500,000 in AGI. 
  • 401K – Does not change limits. Does eliminate ability to re-characterization traditional to Roth IRA.

Have a wonderful month!

Marcy A. Wagner
TitleCore National


Take advantage of an IMA membership in 2018
Be on the lookout for your IMA membership renewal for 2018. Renewal forms will be in the mail in early December and are also available on the IMA website. The IMA is planning another great year, continuing to make significant strides to improve the mortgage industry. We encourage to you join forces with your fellow mortgage professionals and take advantage of all the IMA has to offer.


CFPB launches beta version of new HMDA platform
The Consumer Financial Protection Bureau (CFPB) has launched a beta version of its new platform for reporting Home Mortgage Disclosure Act (HMDA) data. The beta version allows bankers to familiarize themselves with the new system by creating test login credentials, uploading and validating sample HMDA data files, reviewing edits and filing test data. 

Bankers may make unlimited tests using the beta system. All test accounts and data will be removed from the system when the filing period opens in January 2018. Access the platform.

“Key” HMDA data fields identified
The federal regulatory agencies – Federal Deposit Insurance Corporation (FDIC), Office of Comptroller of the Currency (OCC) and Federal Reserve System – announced they have identified the “key” Home Mortgage Disclosure Act (HMDA) data fields “to support the efficient and effective evaluation of financial institutions’ compliance with HMDA’s requirements.” The agencies will focus examination-related testing of HMDA data on the 37-identified “key fields.” Key fields are those fields considered to be most important to ensuring the integrity of analyses of overall HMDA data. The key field guidance can be found here.

Separately, the Federal Financial Institutions Examination Council (FFIEC) members issued FFIEC HMDA Examiner Transaction Testing Guidelines (Guidelines) for the FFIEC members’ examination staff to use in assessing the accuracy of the HMDA data that financial institutions record and report. The guidelines include a data sampling process that involves prioritizing designated data fields for review or reviewing all data fields within a sample. However, the guidelines do not establish designated key data fields. In an effort to promote efficiency, coordination and consistency, the Federal Reserve, FDIC, and OCC have jointly identified and designated 37 of the HMDA data fields to be collected beginning Jan. 1, 2018, as designated key HMDA data fields. In identifying key data fields, a variety of factors were considered, including HMDA’s requirements, the goal of ensuring the efficiency of bank examinations, the effective validation of HMDA data important to evaluating compliance with the Community Reinvestment Act and fair lending requirements as well as the likelihood that a data field would be reported correctly based on past examination experience.

CFPB updates compliance resources
The Consumer Financial Protection Bureau (CFPB) has updated a number of its compliance resources to support implementation of the recently issued revisions to many of its mortgage rules.

  • TRID Resources – The CFPB published an updated TILA-RESPA Integrated Disclosure Small Entity Compliance Guide (Version 5) which incorporates amendments and clarifications included in a final rule issued July 7, 2017, that provided clarifications and revised many aspects of the original TRID rule. The updated guide can be found on the CFPB’s dedicated implementation webpage. Shortly after the release of the final rule, the CFPB issued a 25-page detailed summary. As a reminder, the amendments to TRID became effective Oct. 10, 2017, with optional compliance until Oct. 1, 2018. On Oct. 1, 2018, compliance with the amendments becomes mandatory.
  • HMDA Resources – The CFPB also updated the Home Mortgage Disclosure Act Small Entity Compliance Guide (Version 2.0) which incorporates changes implemented via the 2017 HMDA final rule released on Aug. 24, 2017. The updated Small Entity Guide can be found here. The CFPB also published a new chart, Reportable HMDA Data: A Regulatory and Reporting Overview Reference (“Reporting Reference Chart”) intended to be used as a reference for data points required to be collected, recorded and reported under Regulation C. The 34-page Reporting Reference Chart combines the contents of the Summary of Reportable Data and Reporting “Not Applicable” charts with the filing instructions for that data. In addition, the 2018 Filing Instructions Guide (FIG) was revised to reflect updates to the name code for Freddie Mac’s Automated Underwriting System (AUS) and AUS results, guidance on reporting government monitoring information (GMI) collected on the basis of visual observation or surname for applicable loans and other minor clarifications. 

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