CUNA outlined a number of concerns with the Consumer Financial Protection Bureau’s (CFPB) proposed policy guidance on disclosure of loan-level Home Mortgage Disclosure Act (HMDA) data, it wrote to the bureau last week.
The proposed policy guidance applies to HMDA data to be reported effective January 2018. Beginning next year, lenders will need to report additional data points to the CFPB under HMDA, and some of that data will be made available to the public starting in 2019.
“While we appreciate the Bureau’s proposed modification of certain reportable loan-level data in an effort to reduce risks to consumers, we remain concerned about the large amount of publicly-disclosed, sensitive information that is now required. Public disclosure of this data creates substantial privacy concerns and does not help further achieve the intent of HMDA, which is to provide the public with information necessary to show whether financial institutions are serving the housing credit needs of their communities. Even with the proposed modifications, we believe public disclosure of much of this data raises significant privacy concerns.”
The proposed policy guidance specifies certain data points that will either not be disclosed or will be disclosed with less precision (such as an age range of an applicant/borrower rather than a specific age) in order to reduce the chances the individual can be personally identified.
CUNA supports the data points that will not be disclosed under the proposal, but asks the CFPB to consider excluding additional data points from disclosure in order to further ensure consumer protection.
CUNA also cited concerns with the CFPB’s data security standards and urged the bureau to take steps recommended by the GAO and CFPB’s OIG to enhance its overall data and cybersecurity.