The CFPB’s proposed changes to the Home Mortgage Disclosure Act data collection are excessively broad and complex — and unnecessary to meet HMDA’s goals, ABA and the state bankers associations said in a comment letter.
The CFPB is seeking to add several new Dodd-Frank Act-mandated categories, plus more that it deemed important for its mortgage rulemaking efforts. The bureau proposed a threshold for HMDA reporting of 25 mortgages originated annually.
The associations objected to the inclusion of data not required by Dodd-Frank or by HMDA, noting that the extra data represents a “nightmare of complexities” and a massive compliance burden. “HMDA was not intended to be an uncompensated appropriation of proprietary business information to populate a national mortgage database,” they said.
The groups also objected to the “patently over-inclusive” 25-loan reporting threshold, recommending that it be raised to 250 loans per year. They also called for better protections for consumer privacy and assurances that in attempting to comply with the more complex reporting requirements, lenders will not be cited for reporting errors not associated with fair lending violations.
HMDA data are collected to help regulators evaluate compliance with fair lending laws. The associations emphasized that there is no evidence of fair lending violations on a scale to warrant the bureau’s proposed expansion of HMDA data — and no evidence that the expansion will improve mortgage compliance.
Read the letter from ABA and the state associations.
Read ABA’s joint letter with other national trade groups.