Representatives from CUNA and several credit unions met with the CFPB this week to discuss the Home Mortgage Disclosure Act (HMDA) and the CFPB’s resubmission guide. Representatives from the various prudential regulators also joined the meeting by phone. 

During the meeting, CUNA staff and members reiterated the points raised in our recent comment letter and urged the agency to provide credit unions with as much leeway as possible on the resubmission thresholds. While the prudential regulators on the call did not comment during the meeting, CFPB staff asked several questions on the details of HMDA reporting difficulty. The dramatic increase in the number of data points that are required under the recently finalized HMDA rule will inherently increase the error rate proportionately.  Privacy concerns with the data as well as the operational challenges that go along with retooling systems to account for the newly mandated collection were discussed in depth.  We will continue to follow up with the CFPB on the various questions raised in the meeting.