NAFCU statement on CFPB’s proposed HMDA reporting threshold changes

WASHINGTON, DC (July 24, 2014) — The National Association of Federal Credit Unions (NAFCU) today issued the following statement regarding the Consumer Financial Protection Bureau’s (CFPB) proposal to revise the reporting requirements and thresholds under the Home Mortgage Disclosure Act (HMDA).

“NAFCU and our members support collecting and providing reasonable data for a specific reason,” said NAFCU Director of Regulatory Affairs Mike Coleman. “While we appreciate the proposal’s efforts to amend institutional and transactional coverage, we believe the Bureau should further eliminate unnecessary burden to credit unions and restrict its changes to the HMDA dataset to those mandated by Dodd-Frank.”

Under the proposed rule, depository and non-depository institutions meeting all other criteria under Regulation C, and which had originated 25 or more covered loans in the previous calendar year, would be required to report HMDA data.

The proposal would also expand the number of transactions subject to Regulation C – but eliminate the requirement to report unsecured home improvement loans.

In addition, the Bureau would require institutions to report new data points in order to give regulators a better view of developments in all segments of the housing market. The proposed additional data points include:

information about applicants and borrowers including age, credit score, and debt-to-income ratio;
information about the property securing the loan, such as property value and the number of individual units;
information about loan features, such as loan term, interest rate, and introductory rate period; and,
unique identifiers, such as a universal loan identifier, the property address, and loan originator identifier.
The CFPB is also proposing that financial institutions with large numbers of reported transactions submit HMDA data on a quarterly basis rather than an annual basis.

In addition, the Bureau is proposing to allow HMDA reporters to make disclosure statements available through a publicly available website. The proposal would also add instructions to Appendix A and staff commentary to Regulation C to address questions and concerns that have been raised repeatedly by stakeholders over the years.

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The National Association of Federal Credit Unions is the only national trade association that exclusively represents the interests of federally chartered credit unions before the federal government and the public.

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