ICBA and NAFCU Press CFPB on HMDA Changes

May 25, 2017
The banking and credit union industries may not agree on many things, but they are in agreement that the Consumer Financial Protection Bureau (CFPB) needs to rethink the changes to the Home Mortgage Disclosure Act (HMDA) that is due to take effect on Jan. 1, 2018.
 
The Independent Community Bankers of America (ICBA) sent a letter to the CFPB warning that increased level of data-collection and -reporting related to the HMDA changes would force many community banks out of the residential mortgage market.
 
“These changes are just the latest in an unprecedented number of new and amended consumer regulatory requirements put into effect over the past several years,” ICBA Assistant Vice President and Regulatory Counsel Joe Gormley wrote. “ICBA understands that some of this change was required by statute, but we strongly urge the CFPB to mitigate the impact of the new HMDA requirements on community banks.”
 
Separately, the National Association of Federally-Insured Credit Unions (NAFCU) Regulatory Affairs Counsel Andrew Morris wrote a letter to the CFPB urging for a one-year delay in the HMDA changes to help compliance preparation efforts. He echoed the ICBA’s concerns about smaller lenders being damaged by these changes.
 
“As financial cooperatives directed by volunteer boards, credit unions exist for the primary purpose of serving their membership,” he wrote. “Under current reporting thresholds, the collection of a vastly expanded HMDA dataset from credit unions that do not originate a significant number home mortgage loans would be counterproductive and ultimately harm access to credit. Accordingly, NAFCU urges the Bureau to consider amendments that would raise the reporting threshold for close-end mortgage loans in Section 1003.2(g) of the Final Rule. NAFCU believes that by raising the reporting threshold, smaller credit unions will be spared unreasonable compliance costs that would otherwise impact their capacity to originate affordable mortgages.”
Compliance