League Submits HMDA Comment Letter Opposing Any Changes That Represent Added Compliance Burden for CUs

Your League today submitted a comment letter in response to the Consumer Financial Protection Bureau's (CFPB) request for information on the Home Mortgage Disclosure Act. In our letter, we note our strong support for fair lending, but our opposition to any changes that would exacerbate an already burdensome and complex reporting system.

We support CFPB's review of this rule, and believe a narrower set of data can achieve the statutory goals.

"The CFPB has issued charts, compliance guides, FAQs, supervisory guidance and other materials to assist with compliance. However, the small entity compliance guide alone is 132 pages long," says our letter. "Simply put, this is an extremely difficult regulation to implement as it is complex; changes to the regulation, even if designed to ultimately give institutions relief, are difficult to execute."

"Credit unions support fair lending and oppose any changes to HMDA that would require additional reporting or additional burden. We would oppose reducing existing thresholds or adding more data points. In addition, we would ask the CFPB to assess whether the reporting of open-end lines of credit fulfills any statutory goals of HMDA."

Read the letter

• Related: HMDA Disproportionately Burdens Credit Unions
• Related: CFPB Urged by NAFCU to Make Changes to its Assessment of HMDA