115-174 on May 22, 2018, and President Donald Trump signed it into law on May 24, 2018. 115-174 changes a number of financial regulations; its six titles alter certain aspects of the regulation of banks, capital markets, mortgage lending, and credit reporting agencies. Others are designed to relax mortgage lending rules and provide additional protections to consumers, including protections related to credit reporting, veterans' mortgage refinancing, and student loans. Some P.L. 115-174 provisions amend the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act; P.L. Proponents of the legislation assert it provides targeted financial regulatory relief that eliminates a number of unduly burdensome regulations, fosters economic growth, and strengthens consumer protections. Opponents of the legislation argue it needlessly pares back important Dodd-Frank safeguards and protections to the benefit of large and profitable banks. 115-174 , as passed, can be grouped into one of five issue areas: (1) mortgage lending, (2) regulatory relief for "community" banks, (3) consumer protection, (4) regulatory relief for large banks, and (5) regulatory relief in securities markets. 115-174 generally provided important consumer protections. In addition, P.L. 115-174 argue that the new compliance option will expand credit availability and appropriately align the incentives of the borrower and lender, critics of the proposal counter that the incentives of holding the loan in portfolio are insufficient to protect consumers and that the protections in the rule in place prior to the enactment of P.L. Section 104—Home Mortgage Disclosure Act Adjustment

				Provision

Section 104 exempts banks and credit unions from certain Home Mortgage and Disclosure Act (HMDA; P.L. 94-200 ) reporting requirements—generally new requirements implemented by the Dodd-Frank Act. It also provided additional disclosure requirements. Regulatory Relief for Community Banks

Title II of P.L. Although some provisions relax certain regulations for all banks, Title II provisions are generally aimed at providing regulatory relief to institutions under certain asset thresholds. Whether multiple risk-based capital ratios should be replaced with a single leverage ratio is subject to debate. Section 203 and 204—Changes to the Volcker Rule

				Provision

Section 203 creates an exemption from prohibitions on propriety trading—owning and trading securities for the bank's own portfolio with the aim of profiting from price changes—and relationships with certain investment funds for banks with (1) less than $10 billion in assets, and (2) trading assets and trading liabilities less than 5% of total assets. Analysis

By lengthening the time fraud alerts stay on credit reports and by allowing consumers to place security freezes on their credit reports, Section 301 gives consumers the ability to make it more difficult for identity thieves to get credit using a victim's identity. To address this issue, Section 307 extends consumer protections of the ability-to-repay requirement to PACE loans. Regulatory Relief for Large Banks

Title IV is intended to provide regulatory relief to certain large banks. Specifically, under criteria set by Dodd-Frank and the Basel III accords, organizations were divided into the following three tiers that determine which enhanced regulations they are subject to
1. about 38 U.S. bank holding companies or the U.S. operations of foreign banks with more than $50 billion in assets; 2. a subset of 15 a dvanced a pproaches banks with $250 billion or more in assets or $10 billion or more in foreign exposure; and 3. a further subset of g lobally s ystemically i mportant b anks (G-SIBs), designated as such based on a bank's cross-jurisdictional activity, size, interconnectedness, substitutability, and complexity. Large banks are also subject to other Basel III regulations that are not directly affected by P.L. 115-174 automatically exempts banks with assets between $50 billion and $100 billion from enhanced regulation, except for the risk committee requirements. Banks with between $100 billion and $250 billion in assets will still be subject to supervisory stress tests, and the Fed has discretion to apply other individual enhanced prudential provisions (except for most of those included in the "Financial Stability" bullet above) to these banks if it would promote financial stability or the institutions' safety and soundness. 115-174 generally agree that enhanced prudential regulation should apply to systemically important banks, but disagree about which banks could pose systemic risk. Capital Formation

Title V of P.L. No longer being classified as an investment company under the ICA reduces the qualifying fund's registration and disclosure requirements. In addition, prior to the enactment of P.L. Insurance . Federal Reserve Surplus.
Some observers assert the financial crisis of 2007-2009 revealed that excessive risk had built up in the financial system, and that weaknesses in regulation contributed to that buildup and the resultant instability. In response, Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203; the Dodd-Frank Act), and regulators strengthened rules under existing authority. Following this broad overhaul of financial regulation, some observers argue certain changes are an overcorrection, resulting in unduly burdensome regulation.
The Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155, P.L. 115-174) was signed into law by President Donald Trump on May 24, 2018. P.L. 115-174 modifies Dodd-Frank provisions, such as the Volcker Rule (a ban on proprietary trading and certain relationships with investment funds), the qualified mortgage criteria under the Ability-to-Repay Rule, and enhanced regulation for large banks; provides smaller banks with an "off ramp" from Basel III capital requirements—standards agreed to by national bank regulators as part of an international bank regulatory framework; and makes other changes to the regulatory system.
Most changes made by P.L. 115-174 can be grouped into one of five issue areas: (1) mortgage lending, (2) regulatory relief for "community" banks, (3) consumer protection, (4) regulatory relief for large banks, and (5) regulatory relief for capital formation.
Title I of P.L. 115-174 relaxes or provides exemptions to certain mortgage lending rules. For example, it creates a new compliance option for mortgages originated and held by banks and credit unions with less than $10 billion in assets to be considered qualified mortgages for the purposes of the Ability-to-Repay Rule. In addition, P.L. 115-174 exempts certain insured depositories and credit unions that originate few mortgages from certain Home Mortgage Disclosure Act reporting requirements.
A number of Title II provisions provide regulatory relief to community banks. For example, banks with under $10 billion in assets are exempt from the Volcker Rule, and certain banks that meet a new Community Bank Leverage Ratio are exempt from other risk-based capital ratio and leverage ratio requirements.
Title III enhances consumer protections in targeted areas. For example, it subjects credit reporting agencies (CRAs) to additional requirements, including requirements to generally provide fraud alerts for consumer files for at least a year and to allow consumers to place security freezes on their credit reports. In addition, it requires CRAs to exclude certain medical debt from veterans' credit reports.
Title IV alters the criteria used to determine which banks are subject to enhanced prudential regulation from the original $50 billion asset threshold original set by Dodd-Frank. Banks designated as global systemically important banks and banks with more than $250 billion in assets are still automatically subjected to enhanced regulation. However, under P.L. 115-174 banks with between $100 billion and $250 billion in assets are automatically subject only to supervisory stress tests, while the Federal Reserve (Fed) has discretion to apply other individual enhanced prudential provisions to these banks. Banks with assets between $50 billion and $100 billion will no longer be subject to enhanced regulation, except for the risk committee requirement. In addition, P.L. 115-174 relaxes leverage requirements for large custody banks, and allows certain municipal bonds to be counted toward large banks' liquidity requirements.
Title V provides regulatory relief to certain securities regulations to encourage capital formation. For example, it exempts more securities exchanges from state securities regulation and subjects certain investment pools to fewer registration and disclosure requirements.
Title VI provides enhanced consumer protection for borrowers of student loans. For example, it requires CRA to exclude certain defaulted private student loan debt from credit reports.
Proponents of P.L. 115-174 assert it provides necessary and targeted regulatory relief, fosters economic growth, and provides increased consumer protections. Opponents of the legislation argue it needlessly pares back important Dodd-Frank protections to the benefit of large and profitable banks.