The Credit Union National Association (CUNA) and several credit unions met with the Consumer Financial Protection Bureau (CFPB) this week to discuss the Home Mortgage Disclosure Act (HMDA) and the bureau’s resubmission guidelines. CUNA reiterated the points it made in its March 11 comment letter, urging the CFPB to provide credit unions with as much leeway as possible on the resubmission thresholds.
The CFPB issued its final HMDA rule in October 2015, significantly expanding the number of data points required under the act, expansion that goes far beyond the required number of data points spelled out in the Dodd-Frank Act.
The dramatic increase in the number of required data points will inherently escalate the error rate proportionately, CUNA believes, and passed those concerns onto the CFPB during this week’s meeting.
CUNA is also concerned about a lack of information of what data points will be made public, as well as the operational challenges that go along with retooling systems to account for the newly mandated collection.
CUNA, the credit unions and the bureau discussed these topics in depth, and CUNA will continue to follow up with the bureau going forward on the questions raised at the meeting.