Berger urges Cordray to delay HMDA rule
Berger emphasized the importance of giving credit unions more time to implement the new provisions, and he urged that the effective date be delayed to Jan. 1, 2019.
"The Bureau's pending proposal to 'fix' various issues within the HMDA Final Rule is a step in the right direction," Berger wrote in a letter to Cordray. "Credit unions appreciate measures taken by regulators intended to correct errors and offer additional clarifications … That being said, no amount of 11th hour tinkering with technical amendments can offset the tremendous burden being hoisted upon credit unions and their vendors as a result of the Final Rule."
"As we continue to inch toward the fixed effective date, NAFCU has heard increasing levels of concern from credit unions and their vendors over preparations for the Final Rule," Berger added. "In order to facilitate a smooth transition to the new HMDA requirements, it is critical that credit unions and their vendors are provided enough time to ensure they are adequately prepared before the ultimate effective date."
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.
The CFPB proposal includes a number of clarifications, technical corrections and minor changes to the HMDA regulation, including clarifying certain key terms, such as "temporary financing" and "automated underwriting system." Proposed changes also establish transition rules for reporting certain loans purchased by financial institutions and facilitate reporting the census tract of a property with a new geocoding tool the CFPB plans to provide online.
NAFCU has a host of HMDA compliance resources available to association members, including charts and guides, articles, webcasts and blog posts.
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