news.cuna.org/articles/117489-cfpb-announces-hmda-credit-card-reporting-covid-19-relief
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CFPB announces HMDA, credit card reporting COVID-19 relief

March 26, 2020

The Consumer Financial Protection Bureau (CFPB) Thursday announced several changes called for by CUNA to allow financial institutions flexibility during the coronavirus disease (COVID-19) outbreak. CUNA President/CEO Jim Nussle discussed suggestions to help credit unions better serve their members during a call with CFPB Director Kathy Kraninger and followed up with a letter detailing credit union issues.

The CFPB will not expect reporting:

  • By certain mortgage lenders as required under the Home Mortgage Disclosure Act (HMDA) and Regulation C. The CFPB notes that entities should continue collecting and recording HMDA data in anticipation of making annual submissions. The CFPB will provide information on when and how institutions will be expected to commence what would have been new quarterly HMDA data submissions; and
  • Of certain information related to credit card and prepaid accounts under the Truth in Lending Act, Regulation Z, and Regulation E. This includes the annual submissions concerning agreements between credit card issuers and institutions of higher education; quarterly submission of consumer credit card agreements; collection of certain credit card price and availability information; and submission of prepaid account agreements and related information.

CUNA’s letter requested that both be postponed.

To the extent the submission of information is required by law, the CPPB is issuing policy statements indicating that it does not intend to cite in an examination or initiate an enforcement action against any entity for failure to submit such information when required. The CFPB will notify entities at a later date of when and how to submit information under these requirements. 

CUNA also requested the CFPB adopt a policy of “good faith efforts toward substantial compliance” during the examination process once they resume after the pandemic.

According to the CFPB it will, when conducting examinations and other supervisory activities and in determining whether to take enforcement action, “consider the circumstances that entities may face as a result of the COVID-19 pandemic and will be sensitive to good-faith efforts demonstrably designed to assist consumers.”