Recent regulatory activity has kept the industry writing comment letters in droves, but now is no time to stop writing letters! The CFPB recently proposed a rule updating the reporting requirements of the Home Mortgage Disclosure Act (HMDA). Significant provisions in the proposal include; an adjustment to the covered entities that must report HMDA data, which loans have to be reported, and the specific data that must be reported from each covered loan.
Credit unions that meet the existing criteria to qualify as a reporting entity under HMDA would be required to report their information only if they originate 25 or more covered loans other than open-end lines of credit and commercial lines of credit, in the previous calendar year. This would eliminate the reporting requirement for credit unions that meet the asset size threshold and other criteria but have a low volume of loans. While unsecured home improvement loans would no longer have to be reported all closed-end loans, open-end lines of credit and reverse mortgages secured by dwellings would have to be reported.
The proposal includes the additional reporting information as mandated by the Dodd-Frank Act. However, you will find that the CFPB used its discretionary authority to expand the information that must be reported beyond what is required in the Dodd-Frank Act. The CFPB believes the additional data points should be reported to improve market information and monitor access to credit.
Comments are due to the CFPB by October 22, 2014 so start writing your letters!