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Removing Barriers Blog

Comment Letter to CFPB on HMDA Regulation C
Posted June 11, 2015 by CUNA Advocacy

Today CUNA sent a letter to the CFPB Director Cordray reiterating our serious concerns with proposed Home Mortgage Disclosure Act (HMDA) Regulation C data reporting requirements.

In the letter, CUNA President/CEO Jim Nussle urged the CFPB to only require collection and reporting of those data points required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (The Dodd-Frank Act). CUNA took issue with the volume of required data fields in the proposed rule, expressing that only those required by statute, under Dodd-Frank, should be applied to credit unions.     

We also encouraged the CFPB to change the examination threshold from the current limit of those lenders who originated less than 25 mortgage loans per year to 500 per year.

Particularly Mr. Nussle took issue with the potential impact of the proposed rule on small credit union mortgage lenders. Nussle wrote, "My concern is that the bureau has gone far beyond the purpose of the statute resulting in a proposed rule that would be detrimental to credit unions and their members."  

Lastly, Nussle expressed concern that the proposed rule does not fully recognize the differences between credit unions and the other types of depository institutions, who not only are more closely linked to past lending problems but also have more extensive compliance resources.

Look out for more information on this rule later this summer when the final rule is expected.