National Association of Federally-Insured Credit Unions (NAFCU) Regulatory Affairs Counsel Andrew Morris today in a letter to the Consumer Financial Protection Bureau (CFPB) urged the bureau to limit public disclosure of HMDA loan data in order to protect the privacy of sensitive consumer information.
"NAFCU believes that the CFPB must take an active role in minimizing access to sources of non-public, private information—such as income—that could enable or facilitate financial fraud or identity theft, said Morris. "The proposed policy guidance downplays the risk of an adversary combining pre-existing knowledge about specific applicants or borrowers to re-identify them in HMDA data."
Morris also expressed concern about the cybersecurity risks and the ability to re-identify borrowers with the disclosure of additional HMDA data. He recommended that the CFPB maintain publicly disclosed data similar to its current state.
NAFCU has a host of HMDA compliance resources available to association members, including charts and guides, articles, webcasts and blog posts.