NAFCU letter to CFPB underscores benefits of HMDA delay

WASHINGTON, DC (December 5, 2017) — National Association of Federally-Insured Credit Unions (NAFCU) President and CEO Dan Berger today sent a letter to CFPB Interim Director Mick Mulvaney requesting that the bureau delay the effective date of the Home Mortgage Disclosure Act (HMDA) final rule, allow a voluntary compliance period and execute a “good faith efforts” policy for examinations.

NAFCU previously requested a one-year delay of HMDA’s implementation date, which is currently less than a month away, and stated that a delay would allow a smooth, least-cost transition for credit unions.

“As not-for-profit, member-owned financial institutions, credit unions have a proven track-record of affordable and responsible lending in their communities,” said Berger. “NAFCU and our members support the intended purpose of HMDA, which is the promotion of fair lending and ensuring equitable access to credit in the housing market.  However, throughout the rulemaking process, NAFCU and our members have expressed concerns regarding the Bureau’s significant expansion of HMDA.  As currently drafted, the HMDA rulemaking has and will likely continue to have a substantial role in increasing the overwhelming costs associated with regulatory compliance, which is taxing credit unions’ finite resources.”

Based on the feedback from NAFCU member credit unions, Berger recommended the bureau take a flexible approach to ensuring compliance with the final HMDA rule. This would be accomplished by allowing voluntary compliance with the rule starting Jan. 1, but delaying mandatory compliance until Jan. 1, 2019, and adopting a policy for the bureau to consider an institution’s “good faith efforts” during examinations until 2020.

“In order to facilitate a smooth transition to the new HMDA requirements, it is critical that credit unions and their vendors are afforded enough time to ensure they are appropriately prepared before any mandatory compliance date,” said Berger.

To read the full letter, please click here.


The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to or @NAFCU on Twitter.


Molly Safreed, (NAFCU)

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