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Sept. 2, 2014 – NAFCU published a Regulatory Alert seeking comments on the CFPB's proposed changes to the reporting requirements under the Home Mortgage Disclosure Act.

Comments are due to NAFCU by Sept. 17, in order to prepare the association's comment letter for the bureau by its deadline of Oct. 29.

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 make significant changes to the types of loans that are subject to HMDA reporting under Regulation C. It would expand the scope of reportable transactions to include all closed-end loans, open-end lines of credit, and reverse mortgages secured by dwellings, regardless of the purpose of the loan or line of credit. Under this proposed expansion, it would be mandatory to report Home Equity Lines of Credits (HELOCs).

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:

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 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.