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NAFCU Senior Counsel for Research and Policy Andrew Morris wrote to the Treasury Department to share NAFCU’s concerns with an information collection proposal for Emergency Capital Investment Program (ECIP) participants, which requests that ECIP participants report demographic information for all loans so the Treasury can measure qualified lending activity.

In the letter, Morris urges the Treasury Department to reconsider the scope of the information collection to limit detailed demographic reporting to only Home Mortgage Disclosure Act (HMDA) reportable mortgage loans. Additionally, he requests that the agency provide more guidance on how demographic information should be collected.

If the Treasury Department opts not to alter the scope of the information ECIP participants need to collect, Morris asked the agency to provide a longer grace period in alignment with the phase-in of the CFPB's small business data collection rule implementing section 1071 of the Dodd-Frank Act.

Read the full letter. NAFCU will continue to engage the Treasury Department to prevent further operational burdens on credit unions.