CCUL submits letter on CFPB proposal to temporarily raise HMDA reporting threshold
Wednesday, August 2, 2017
In response to the Consumer Financial Protection Bureau’s (CFPB) request for comment on the proposed rule to temporarily raise the HMDA reporting threshold, the Carolinas Credit Union League (CCUL) recently submitted a comment letter sharing its recommendations.
The CFPB’s latest proposal builds upon a 2015 final rule amending HMDA (Home Mortgage Disclosure Act), which includes a new requirement on the collection and reporting of data concerning open-end lines of credit. Within that requirement, effective January 1, 2018, is an exclusion for credit unions that originate fewer than 100 open-end lines of credit in the two preceding calendar years.
CFPB now seeks to temporarily increase the reporting exclusion from 100 to 500 open-end lines of credit through calendar years 2018 and 2019, so credit unions would not be required to begin collecting such data until January 1, 2020.
In the letter, VP, Compliance & Regulatory Counsel Jeanne Couchois states, “In general, CCUL supports a temporary increase to the threshold but considers 1,000 open-end lines of credit to be more appropriate. It is CCUL’s position that the CFPB not only raise the temporary threshold to 1,000 but make the increase in the threshold permanent instead of just the two years outlined in the proposed rule.”
“In the proposed rule, the CFPB states that it “did not have robust data for making the estimates that went into establishing the open-end coverage threshold.” Until the agency has more accurate data credit unions should not be subject to rules that are burdensome,” Couchois added.
Login to read the full letter here.