Benefits from add’l HMDA data points do not outweigh burdens

October 17, 2019

The Consumer Financial Protection Bureau (CFPB) should eliminate data points required by its 2015 Home Mortgage Disclosure Act (HMDA) rule but not required by Dodd-Frank. CUNA submitted its comment letter Wednesday to the CFPB on its advance notice of proposed rulemaking on HMDA data points and coverage.

“While CUNA understands and supports the purpose of HMDA, we believe any benefits obtained from the data points added by the 2015 HMDA rule pursuant to the CFPB’s discretionary authority will not outweigh the cost and burden to credit unions. We therefore urge the CFPB to eliminate the data points added in Regulation C pursuant to the CFPB’s discretionary authority.”

CUNA is concerned that the CFPB’s current approach of numerous rule revisions is particularly expensive for smaller credit unions and can rob consumers of affordable and efficient financial services options. CUNA recommends the CFPB update rules “only when critically necessary to ensure preservation of consumer protection.”

The letter also reiterated CUNA’s recommendation that the CFPB restrict the data set to data points required by the Dodd-Frank Act, as the CFPB’s 2015 HMDA rule nearly doubled the amount of data points required for submission.

“If the Bureau does not eliminate all discretionary data points in Regulation C, then it should, at a minimum, eliminate all the discretionary data points that do not further the purposes of HMDA,” the letter reads. “In this review, the Bureau should evaluate which required data points are superfluous or unnecessary… The Bureau should articulate its analysis and decision-making process if it decides a discretionary data point is among the required HMDA reporting for credit unions.”