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NAFCU President and CEO Dan Berger on Monday reiterated the association's request that the CFPB delay the effective date of the Home Mortgage Disclosure Act (HMDA) final rule, allow a voluntary compliance period and execute a "good faith efforts" policy for examinations to allow a smooth, least-cost transition for credit unions.

The requests were sent in a letter to CFPB Interim Director Mick Mulvaney. Berger had previously requested a one-year delay of HMDA's implementation date, which is currently less than a month away, in a letter sent to Mulvaney after he was named acting director of the bureau.

Based on the feedback from NAFCU's member credit unions, Berger recommended the bureau take a flexible approach to ensuring compliance with the final HMDA rule. This would be accomplished by allowing voluntary compliance with the rule starting Jan. 1 but delaying mandatory compliance until Jan. 1, 2019, and adopting a policy for the bureau to consider an institution's "good faith efforts" during examinations until 2020.

Berger wrote that those concessions "would permit credit unions to select the reporting option best suited for their individual institution based on their specific level of preparedness while still allowing those credit unions to rely on an official policy that good faith efforts towards compliance will be taken into consideration during examinations."

"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 continued. "In effect, a voluntary compliance period would permit reporting institutions to test their systems in a 'real world' environment."

To read Berger's full letter to Mulvaney, click here.