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August 01, 2019

CFPB reopens comments on HMDA threshold proposal

CFPBThe CFPB has reopened the comment period on its proposal to raise the Home Mortgage Disclosure Act's (HMDA) transactional and institutional reporting thresholds. Comments are reopened until Oct. 15 to allow the public to review the Federal Financial Institutions Examination Council's national loan level data set and the CFPB's review of that data – which are expected to be released later this summer – and provide additional comments on the proposal.

In June, NAFCU submitted comments on the threshold proposal prior to the initial comment deadline. The association offered support for increasing the thresholds and also offered specific suggestions to provide even more relief to credit unions. NAFCU noted that "HMDA reporting for credit unions has a disproportionate cost impact because these institutions often lack the scale, sophistication, and bargaining power to easily implement fully-automated reporting systems."

NAFCU will review the national data once released and consider additional feedback. Credit unions that did not submit comments to the CFPB during the first period are encouraged to do so during this reopened opportunity.

The bureau also recently extended the comment period on its advance notice of proposed rulemaking (ANPR) related to data collection and reporting requirements under HMDA.

Credit unions and other covered institutions reported their first set of HMDA data in March. The CFPB extended the ANPR's comment period by three months – also to Oct. 15 – to allow time to review the submitted data. More information on what feedback the bureau would like can be found in NAFCU's Regulatory Alert.