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As urged by NAFCU, the CFPB and NCUA last week announced their intentions to pursue a "good faith efforts" policy when examining credit union compliance with the Home Mortgage Disclosure Act rule, set to take effect Jan. 1.

NAFCU has submitted letters to both agencies requesting such an approach to examinations because of the significant challenges the rule has created for credit unions.

The CFPB released a statement Thursday announcing it intends to review the 2015 HMDA rule and recognizes that the compliance requirements pose "significant systems and operational challenges." The NCUA on Thursday released its 2018 Supervisory Priorities, which includes HMDA compliance.

Both agencies said their review of 2018 HMDA data "will be diagnostic in nature, designed to help credit unions identify compliance weaknesses in collecting 2018 data for submission in 2019, and will credit good faith compliance efforts." Neither intends to cite institutions for data errors or require data resubmissions unless data errors are material.

In the Dec. 4 letter to Acting CFPB Director Mick Mulvaney, NAFCU President and CEO Dan Berger requested that the bureau do essentially that: Allow a voluntary compliance period and execute a "good faith efforts" policy for examinations, as well as a one-year delay of HMDA's implementation date.

"In addition, if provided a voluntary compliance option, credit unions that are currently prepared to comply with the HMDA expansion may choose to report their data under the new requirements while being protected should any unexpected issues come up," Berger wrote. "In effect, a voluntary compliance period would permit reporting institutions to test their systems in a 'real world' environment."

NAFCU sent a letter to the NCUA last month requesting a "good faith efforts" examination policy after the CFPB highlighted its plan in its Supervisory Highlights, Summer 2017 report.