WASHINGTON (10/26/15)--CUNA’s compliance attorneys are continuing their deep dive into the latest Home Mortgage Disclosure Act (HMDA) requirements and have identified a number of newly required data points.
While the Dodd-Frank Act only requires 17 data points, the Consumer Financial Protection Bureau (CFPB) wants an additional 16 data points to be reported.
CUNA believes the final rule will have a significant impact on any credit union that reports HMDA data or will be required to report such data. The drastic expansion of the new data that financial institutions must collect and report--coupled with the need to change and integrate systems and operations, as well as train staff--will certainly create additional expenses and burden for credit unions.
The CPFB is required by Dodd-Frank to collect information on:
Revisions to these data points include:
The CFPB’s rule would require additional reporting of:
(This article is part of a new News Now series running every Monday, in which CUNA compliance experts will highlight top compliance issues facing the credit union system. Share this link with those who would be interested in a free News Now subscription: http://news.cuna.org/subscribeNN.)