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NAFCU sent two Regulatory Alerts to member credit unions Thursday seeking feedback on the transactional and institutional thresholds used to determine exemptions from reporting requirements under the Home Mortgage Disclosure Act (HMDA), as well as the data points credit unions are required to report.

The Regulatory Alerts were in response to a notice of proposed rulemaking on the thresholds and an advance notice of proposed rulemaking (ANPR) on the costs and benefits of reporting certain data points issued by the CFPB earlier this month.

Thresholds for exemption

In the Regulatory Alert, NAFCU explains that the CFPB's proposed rule formally implements partial exemptions from HMDA's requirements that were added under S. 2155 and also provides two alternatives that would permanently raise the closed-end institutional and transactional coverage threshold to either 50 or 100 closed-end mortgage loans in each of the preceding two calendar years.

The proposal would also extend to Jan. 1, 2022, the current temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage, and thereafter permanently reset the open-end threshold at 200 open-end lines of credit in each of the preceding two calendar years.

NAFCU would like to know if these changes would provide credit unions with meaningful relief and how they would affect operational costs. Credit unions can provide feedback to NAFCU on this proposed rule through its Regulatory Alert until May 29; comments are due to the CFPB June 12.

Data points and coverage

Since credit unions reported their first set of HMDA data in March, the CFPB is evaluating whether financial institutions can provide additional and more accurate information about the collection and reporting process. NAFCU notes that the goal of the ANPR "is to ensure that the data points required balance the benefits and burdens of reporting." In the Regulatory Alert, the association asks credit unions if:

• there are HMDA data points that should be revised or deleted;
• there are HMDA data points that are particularly burdensome to collect, or pose significant operational challenges;
• there are HMDA data points that require more clarity or explanation for collection;
• credit unions should be required to report business or commercial purpose loans made to a non-natural person and secured by a multifamily dwelling; and
• the CFPB should continue the free-form text field answer options.

Credit unions can provide feedback to NAFCU on the ANPR through its Regulatory Alert until June 21; comments are due to the CFPB July 8.