Press

On behalf of the Credit Union National Association, I am writing in support of H.R. 4993, the “Homeowner Information Privacy Protection Act” (HIPPA).  CUNA represents America’s state and federal credit unions and their more than 100 million members.

As you know, the Consumer Financial Protection Bureau (CFPB) recently finalized amendments to Regulation C that would significantly increase the amount of data mortgage lenders, including credit unions, will be required to provide.  The rule will also almost certainly lead to mortgage credit and other credit union services being more expensive and possibly less available to our members, your constituents.

The Bureau will now require credit unions that have originated 25 or more closed-end mortgage loans or 100 or more open-end loans in the prior year to report dozens of data points in addition to what is required under the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act.   Dodd-Frank outlined only 17 data points that Congress intended for the CFPB to collect as part of its HMDA information.  While Congress did authorize the collection of “such other information as the Bureau may require,” the intent of Congress was unlikely to allow the CFPB to more than double the amount of express data points collected.

When implemented, the final CFPB rule will impose significant burden on credit unions beyond what Congress envisioned when enacting the Dodd-Frank Act.  Credit unions will undertake significant expense to bring their systems into compliance with a rule that does very little, if anything, to provide credit union members with additional protection.  Further, the rule will not significantly enhance the ability of the CFPB to oversee the industry.  Instead, it will undoubtedly add to the compliance costs credit unions must pay, a cost that rose to $7.2 billion in 2014.

Your legislation would delay the implementation of the CFPB rule until the Government Accountability Office (GAO) has completed a study on the data the CFPB is requesting from lenders.  Studying the impact of increased data points will ensure that consumer data remains secure and not unnecessarily disclosed.  It is important to do the study before the rule is implemented to identify and reduce the risk of fraud or identity theft. Furthermore, assessing the impact of increased data reporting will ensure that credit unions, which did not cause the financial crisis, are not overly burdened with unneeded data reporting.

We appreciate your efforts to examine the impact of the CFPB rule before the Bureau implements it. Ideally this will result in reduced burden on credit unions and enhanced protection of citizens’ personal identifying information.  Thank you for your efforts on this legislation, and we look forward to working with you as this moves forward.

Sincerely,

Jim Nussle