HMDA amendments a good start, but not enough

While the law lowers the number of institutions reporting, it does not go far enough in keeping certain HMDA data points from being made public.

The Economic Growth, Regulatory Relief, and Consumer Protection Act (SB 2155), among other regulatory relief provisions, amended the 2015 Home Mortgage Disclosure Act to provide partial exemptions from the collection and reporting of the expanded 2015 HMDA data points.

While the law lowers the number of institutions reporting sensitive financial information of mortgage loan applicants, it does not go far enough in that it does not address the issue of keeping certain HMDA data points from being made public. Given the ongoing data security concerns at the Consumer Financial Protection Bureau, the privacy issue must be addressed in a manner that goes much further than what the CFPB proposed in its July 5 statement.

SB 2155 Amendments to 2015 HMDA Rule

In part, the 2015 HMDA rule added 25 new data points on the loan/application register for both closed-end and open-end lines of credit. This rule requires reporting of the new HMDA data points for mortgage-lending institutions that originated at least 25 closed-end mortgage loans or at least 500 open-end lines of credit in each of the two preceding calendar years (i.e., calendar years 2018 and 2019).

 

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