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NAFCU supports the fair lending goals of the Home Mortgage Disclosure Act but finds that CFPB has "failed to provide compelling reasons how the collection of the additional data ensures fair access to credit in the housing market," Regulatory Affairs Counsel Alicia Nealon wrote Wednesday.

"The proposed rule is clearly a result of extensive engagement with industry stakeholders, and we commend the Bureau for its responsiveness to feedback and input from credit unions throughout the HMDA rulemaking process," Nealon wrote Wednesday. "Despite these efforts, NAFCU does not believe the CFPB has given adequate consideration to the burden that the proposed rule would have on small entities."

Under the proposal, 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. While generally supporting the change, Nealon said the transaction threshold should be higher. As for expanding the scope of reportable transactions, she said requiring institutions to submit data on home equity lines of credit, sought for research purposes, would be inappropriate.

In other provisions, the proposal would also require reporting new data points about applicants and borrowers, property used to secure loans, loan features and unique identifiers. Nealon warned these new requirements "would impose a significant regulatory and operational burden on credit unions." As for quarterly reporting by institutions with large numbers of reportable transactions, she said the costs "would significantly outweigh any benefits it might confer."

On the plus side, the proposed rule would allow HMDA reporters to make disclosure statements available through a publicly available website, a move NAFCU welcomes, Nealon noted.