WASHINGTON (12/18/15)--Nineteen members of the U.S. Congress--all members of the House Financial Services Committee--wrote to Consumer Financial Protection Bureau (CFPB) Director Richard Cordray this week expressing numerous concerns about the impact on consumers of recently finalized requirements under the Home Mortgage Disclosure Act (HMDA).
The CFPB finalized new reporting requirements in October, which CUNA believes will add to the already heavy reporting burden faced by credit unions.
“In light of the potential of the new rule to reduce consumer access to mortgage credit, we write to request that the CFPB provide analysis on the effects of applying higher exemption thresholds based on an institution’s annual mortgage origination volume,” the letter reads. “Higher thresholds would help alleviate the potential adverse impact of the final rule.”
The CFPB’s rule exempts institutions originating less than 25 closed-end mortgages and fewer than 100 open-end lines of credit in each of the two preceding years, which covers roughly 1,400 estimates, according to the CFPB.
The legislators wrote that this represents an “infinitesimal fraction” of the nearly 10 million annual mortgage applications reported this year through HMDA.
CUNA pushed for the CFPB to exempt credit unions that originate under 500 mortgage loans per year.
In their letter, the legislators ask the CFPB to provide analysis using closed-end mortgage thresholds of 100, 200, 250 or 500 loans per year.
“We request you provide any analysis the CFPB may have done in the course of preparing its proposed or final rule with regard to the impact of higher loan exemption levels,” the letter reads. “Was the analysis that produced an estimate of 1,400 newly exempt lenders applied to higher exemption levels?”
The final HMDA rule also requires credit unions and banks to collect 48 unique data fields on each mortgage loan made on or after Jan. 1, 2018. This is more than double the number of data fields currently collected, and many more than mandated by the Dodd-Frank Act.
“This large number of data fields represents a significantly higher compliance burden and amplifies the opportunity for any data entry error, especially among institutions that upload this information manually, including many community banks and credit unions,” the letter reads, adding that smaller financial institutions are continuing to struggle under the burden of the post-Dodd-Frank environment.
The letter was signed by Reps. Andy Barr (R-Ky.), Tom Emmer (R-Minn.), Michael Fitzpatrick (R-Pa.), Frank Guinta (R-N.H.), French Hill (R-Ark.), Randy Hultgren (R-Ill.), Blaine Luetkemeyer (R-Mo.), Patrick McHenry (R-N.C.), Luke Messer (R-Ind.), Mick Mulvaney (R-S.C.), Randy Neugebauer (R-Texas), Steve Pearce (R-N.M.), Robert Pittenger (R-N.C.), Bruce Poliquin (R-Maine), David Schweikert (R-Ariz.), Marlin Stutzman (R-Ind.), Scott Tipton (R-Colo.), Lynn Westmoreland (R-Ga.) and Roger Williams (R-Texas).