Removing Barriers Blog

Action Alert: CFPB's Proposal on HMDA
Posted October 07, 2019 by CUNA Advocacy

The CFPB issued a proposed rule to amend the reporting thresholds within the Home Mortgage Disclosure Act (HMDA) Rule. In its proposal, the CFPB would increase the closed-end mortgage loan reporting threshold from 25 loans in each of the prior two years to either 50 or 100 loans. We are supportive of this measure, but are calling on the Bureau to increase the threshold to 500 loans. 

In addition, the proposal would extend until 2022 the temporary open-end line of credit reporting threshold and, after that time, reduce the threshold to 200 lines in each of the prior two calendar years. This reduction – which we do not support – would result in nearly 200 credit unions losing their current exemption from reporting HMDA data on their open-end lines of credit to the CFPB. Instead of adopting this aspect of the proposal, we are calling on the CFPB to return to voluntary reporting of open-end lines of credit – as was the case prior to the 2015 HMDA Rule.

Tell the CFPB to improve the HMDA reporting requirements.