FOR IMMEDIATE RELEASE | November 09, 2017

NAFCU Asks NCUA to Use 'Good Faith Efforts' Policy on HMDA Compliance


Washington (Nov. 9, 2017) – National Association of Federally-Insured Credit Unions (NAFCU) Director of Regulatory Affairs Alexander Monterrubio has asked the NCUA to adopt a "good faith efforts" examination policy, similar to the CFPB, regarding compliance with the Home Mortgage Disclosure Act (HMDA) given the significant challenges the rule has created for credit unions.

In the letter sent today, Monterrubio noted the CFPB's public acknowledgement that it will rely on "good faith efforts" in its initial HMDA compliance examinations and its actions will be "diagnostic and corrective, not punitive." The bureau highlighted its "good faith efforts" plan in its Supervisory Highlights, Summer 2017report.

"Credit unions have been working tirelessly in collaboration with vendors to navigate through the expansive requirements of the new HMDA final rule," Monterrubio wrote. "However, given the rule's complexity and unprecedented scope, NAFCU and our members respectfully request that NCUA adopt the same approach and consider credit unions' 'good-faith efforts' to comply with HMDA during the examination process."

The CFPB's technical amendments to the HMDA rule, issued in August, increase the threshold at which credit unions are required to report home equity lines of credit (HELOCs) from 100 to 500 loans through calendar years 2018 and 2019. NAFCU continues to urge the CFPB for an exemption from HMDA reporting for all HELOCs or, in the alternative, make the 500-loan threshold permanent.

In general, the CFPB's final HMDA rule changes are set to take effect Jan. 1, with most data submissions under the new provisions due in 2019. The rule changes affect HELOCs, establish transactional thresholds for coverage and expand the number of HMDA data points to be collected from credit unions.

The CFPB recently released a beta version of its HMDA portalfor financial institutions to begin testing the reporting process.

NAFCU has a host ofHMDA compliance resourcesavailable to association members, including charts and guides, articles, webcasts and blog posts.

For full text of the letter, please click here.


The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation's federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go towww.nafcu.orgor @NAFCUon Twitter.