CUNA recommended additional amendments to the Consumer Financial Protection Bureau’s (CFPB) Home Mortgage Disclosure Act (HMDA) transaction coverage thresholds that would further relieve unnecessary burdens for credit unions. CUNA filed an initial comment letter on the thresholds in June, and since then the CFPB has published data in several forms on HMDA reporters.
“CUNA supports HMDA’s mission and its mortgage reporting requirements, but its objectives should be balanced by an appropriately tailored regulation… The CFPB has repeatedly acknowledged that credit unions maintained sound credit practices through the economic crisis and did not engage in the practices that led to the crash of the housing market,” the letter reads. “Nevertheless, the HMDA rule has disproportionately burdened credit unions, due to their finite resources, despite no evidence of past wrongful conduct.”
Specifically, CUNA recommends:
CUNA’s analysis shows the current proposal would provide HMDA relief to more than 750 credit unions, but the 500 closed-end threshold would reduce regulatory costs associated with HMDA compliance for more then 1,500 credit unions.
It also shows that if the CFPB implements the proposed decrease to 200 open-end lines after 2022, more than 200 credit unions could lose their current reporting exemption.
“Barring a return to voluntary reporting, the CFPB should make permanent the current 500 open-end line threshold rather than reducing the threshold after a brief extension,” the letter reads.