CUNA appreciates the Consumer Financial Protection Bureau’s efforts to decrease the burden on lenders with limited home equity lines of credit (HELOC), but asked the bureau to consider exempting credit unions, or further increasing the threshold. CUNA’s comment letter came in response to a CFPB proposal to increase the reporting threshold for HELOCs, which was a victory for credit unions.
“While we believe the proposed threshold increase is a step in the right direction, we ask the CFPB to consider whether more can be done in this area. Specifically, we believe a complete exemption from the HELOC reporting requirement would be more appropriate for credit unions and their 110 million members,” the letter reads. “We believe this expanded exemption for credit unions makes more sense given there has been no evidence of wrongful conduct and credit union HELOC data would ultimately be inconclusive because of their field of membership requirements.”
The CFPB’s proposal would raise the threshold for reporting HELOCs under the Home Mortgage Disclosure Act to 500 per year for the next 2 years.
Since the proposal only covers 2 years, CUNA requested the CFPB exempt credit unions entirely from reporting.
CUNA believes elimination of those institutions with a “relatively low” number of HELOCs would be statistically insignificant to the collected data and would not hamper the bureau’s ability to monitor an institution.
CUNA also requested the bureau consider delaying the Jan. 1, 2018 effective date by 1 year to ensure lenders are able to be fully in compliance.