Removing Barriers Blog

CUNA Suggests Improvements to HMDA Reporting Threshold
Posted October 15, 2019 by CUNA Advocacy

Today, CUNA filed a comment letter with the CFPB offering improvements to the HMDA reporting threshold. In response to the Bureau’s reopening of its comment period, CUNA reiterated that the HMDA rule has disproportionately burdened credit unions, despite no evidence of past wrongful conduct.

Therefore, we urge the Bureau to make the following additional amendments to HMDA’s transactional coverage thresholds to further relieve unnecessary regulatory burden for credit unions:

  • Increase the closed-end mortgage loan threshold for required HMDA reporting to 500 loans in each of the prior two years. Barring the adoption of a 500-closed end mortgage loan threshold, the CFPB should finalize the proposed 100 loan threshold at a minimum to exempt credit unions with small mortgage lending portfolios from HMDA reporting.
  • Allow the reporting of open-end lines of credit to once again be voluntary. HMDA reporting for these loans was voluntary prior to the 2015 HMDA Rule, as these loans are separately treated and distinctive from dwelling-secured mortgages.