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NAFCU President and CEO Dan Berger made several recommendations to the CFPB in a letter Wednesday regarding its ongoing review of the agency's Home Mortgage Disclosure Act (HMDA) data collection activities – including limiting the collection to only those fields mandated under the Dodd-Frank Act.

"Credit unions have already incurred substantial costs resulting from system upgrades and hiring of new staff to implement HMDA's vastly expanded requirements," Berger wrote to CFPB Acting Director Mick Mulvaney. "Limiting the number of data points collected would mitigate some of these costs and reduce compliance overhead, giving credit unions more flexibility to grow, develop innovative products, and serve their communities."

Berger added that limiting the HMDA data collection also serves to protect borrower privacy. The CFPB should also limit the public disclosure of HMDA loan data as an added way to protect the privacy of sensitive consumer information, Berger wrote.

Regarding overall privacy concerns, Berger thanked Mulvaney for initiating a review of the CFPB's data security systems to address known risks.