Removing Barriers Blog

CUNA Submits Comments to CFPB on Proposed Threshold Increase for HMDA Reporting
Posted July 28, 2017 by CUNA Advocacy

Earlier this month, the CFPB proposed changes to the HMDA HELOC reporting requirements.  The proposed rule changes the HMDA HELOC reporting requirements from 100 to 500 open-end mortgages for 2018 and 2019.   

Yesterday, CUNA submitted its comments to the CFPB on the proposed rule.  In the comment letter, CUNA acknowledges the CFPB’s effort to decrease the burden on lenders with limited HELOC activity, but also asked the CFPB to consider further increasing the threshold beyond 500.  Since the proposed increase is for two years, CUNA asked the CFPB to consider exempting credit unions entirely from such reporting since credit unions were not the target of the rule.  CUNA also requested the CFPB to consider delaying the January 1, 2018 effective date by one year to ensure lenders are able to be fully in compliance. 

CUNA and the Leagues have been actively engaged urging the CFPB to adjust the reporting requirements and other concerns with the final HMDA rule.  CUNA and America’s credit unions greatly appreciate the CFPB’s recognition that the current HELOC reporting requirements are an unnecessary burden on credit unions and the members they serve.  As the CFPB continues to evaluate this and other rules, CUNA will continue to advocate for meaningful regulatory relief.