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NAFCU Regulatory Affairs Counsel Andrew Morris on Thursday raised the association's concerns about the CFPB's proposed amendments to its Home Mortgage Disclosure Act rule, noting that the amendments do not offset the rule's "tremendous operational challenges."

Morris also reiterated NAFCU's call for the rule's effective date to be delayed by one year to aid compliance efforts.

"While NAFCU appreciates the Bureau's efforts to offer technical corrections and additional clarifications, the proposed amendments do not offset the tremendous operational challenges created by the Final Rule," Morris wrote.

"Under current reporting thresholds, the collection of a vastly expanded HMDA dataset from credit unions that do not originate a significant number home mortgage loans would be counterproductive and ultimately harm access to credit," he continued. "Accordingly, NAFCU urges the Bureau to consider amendments that would raise the reporting threshold for close-end mortgage loans in Section 1003.2(g) of the Final Rule."

Morris noted the association's support for the amendment's corrections of drafting errors in the rule. Morris also raised privacy concerns related to the rule and noted that the CFPB has not yet provided access to a check-digit tool mentioned in the rule.

On Wednesday, NCUA Acting Chairman J. Mark McWatters urged CFPB Director Richard Cordray to use the bureau's exemption authority under Section 1022 of the Dodd-Frank Act to exempt credit unions from the 14 of the 25 new data collection points imposed by the bureau's regulatory actions and not included in the statute.

Most of the new HMDA requirements become effective Jan. 1, 2018. They affect home equity lines of credit, establish transactional thresholds for coverage and expand the number of HMDA data points to be collected from credit unions.

NAFCU has a host of HMDA compliance resources available to association members, including charts and guides, articles, webcasts and blog posts.