HMDA review is a chance to tailor requirements, reduce burdens
Pushing for an increase in the Home Mortgage Disclosure Act (HMDA) reporting threshold, America’s Credit Unions responded to the CFPB’s HMDA data collection request for comment. The comment letter reiterates America’s Credit Unions’ longtime advocacy efforts on this issue.
“Current HMDA reporting requirements impose significant burden on credit unions while often requiring the collection of data that provides little practical supervisory or analytical benefit,” the letter reads. “Although credit unions support HMDA’s transparency and fair lending goals, the scope and structure of the current reporting framework have become overly complex and insufficiently tailored to HMDA’s statutory purposes.”
America’s Credit Unions recommends targeted reductions to HMDA reporting requirements for institutions that remain subject to the rule. This includes scaling back discretionary data points that go beyond HMDA’s statutory requirements and offer limited supervisory or analytical value.
The letter provided additional feedback that the CFPB should eliminate free-form demographic text entries, limit required post-action data updates, and address recurring problems with manufactured housing data that often result in incomplete or inaccurate reporting.