WASHINGTON—CUNA said it supports proposed changes to the Consumer Financial Protection Bureau’s Home Mortgage Disclosure Act (HMDA) rule, but expressed concerns about the impact of the rule itself, and offered several suggestions to ease the regulatory burden on credit unions.
In a letter to the CFPB, CUNA said it is particularly concerned with the lack of information about what collected data will be made public, and in what format it will be made available.
“We support the CFPB’s efforts to fix known issues with the 2015 HMDA Final Rule,” CUNA’s said. “However, the CFPB can and should go much further in addressing known issues with this rule.”
To fix the HMDA rule, CUNA suggested the CFPB:
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Delay the effective date of the HMDA final rule for at least one year or until CFPB has articulated which data points will be made public and in what format (with input from the public under notice and comment procedures).
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Conduct a study regarding the impact on consumer privacy resulting from information made publicly available under HMDA and the potential for identity theft.
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Limit the number of required data points to only those expressly mandated under the Dodd-Frank Act. “Therefore, required data points would not include the additional, extensive CFPB-created data points that add little in the way of useable data to enforce the purpose of HMDA yet create an enormous compliance burden on credit unions,” CUNA wrote.
- Increase the thresholds for compliance with HMDA to 500 for closed-end loans and to 1,000 for open-end loans if the CFPB continues to require home equity line of credit reporting.
CUNA also offered several additions to the proposed changes, including harmonizing several definitions, and noting that despite Bureau claims that the proposal will not add additional costs to financial institutions, “any change to the regulations will create a cost to the institution.”