Removing Barriers Blog

CUNA Raises Concerns with Proposed Disclosure of HMDA Data
Posted December 06, 2017 by dyi

CUNA recently filed a letter with the CFPB citing concerns regarding its proposed policy guidance on disclosure of loan-level HMDA data. 

Beginning next year, lenders will need to report a number of additional data points to the CFPB under HMDA. Some of that data will then be made available to the public by the CFPB and other regulators. The proposed policy guidance specifies certain data points that will either not be disclosed or will be disclosed with less precision (such as an age range of an applicant/borrower rather than a specific age) in order to reduce the likelihood the individual can be personally identified. 

As described in our letter, CUNA supports the data points that will not be disclosed under the proposal but we ask the CFPB to consider excluding additional data points from disclosure in order to further ensure consumer protection. 

With the collection of this additional data, the CFPB will be storing much more personally sensitive information than it has in the past. We cite concerns with the CFPB’s data security standards and urge it to take steps recommended by the GAO and CFPB’s OIG to enhance its overall data and cybersecurity.