CUNA recommended additional amendments to the Consumer Financial Protection Bureau’s (CFPB) Home Mortgage Disclosure Act (HMDA) transaction coverage thresholds that would further relieve unnecessary burdens for credit unions. CUNA filed an initial comment letter on the thresholds in June, and since then the CFPB has published data in several forms on HMDA reporters.
“CUNA supports HMDA’s mission and its mortgage reporting requirements, but its objectives should be balanced by an appropriately tailored regulation… The CFPB has repeatedly acknowledged that credit unions maintained sound credit practices through the economic crisis and did not engage in the practices that led to the crash of the housing market,” the letter reads. “Nevertheless, the HMDA rule has disproportionately burdened credit unions, due to their finite resources, despite no evidence of past wrongful conduct.”
Specifically, CUNA recommends:
- Increasing the closed-end mortgage loan threshold for required HMDA reporting to 500 loans in each of the prior two years. Barring the adoption of a 500-closed end mortgage loan threshold, the CFPB should finalize the proposed 100 loan threshold at a minimum to exempt credit unions with small mortgage lending portfolios from HMDA reporting; and
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