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NAFCU Regulatory Affairs Counsel Dale Baker sent a letter to the CFPB outlining concerns about recent notices from the bureau to credit unions that some data in Home Mortgage Disclosure Act (HMDA) Loan/Application Registers (LARs) over the past three years may be invalid. Baker said the bureau’s expectations detailed in the notices “are wholly unreasonable.”

In the notices, the CFPB indicated that HMDA LARs from 2020, 2021, and 2022 may contain invalid entries in the data field related to street addresses. The notices do not specifically identify the issues and only provide generic examples of why data may be invalid. The bureau instructed affected credit unions to review their submissions and resubmit, if necessary, before the bureau’s HMDA Operations team reanalyzes the data May 15.

“The CFPB is not simply asking credit unions to review a handful of HMDA LAR entries it has identified as potentially invalid,” Baker wrote. “Rather, the CFPB has chosen not to identify the specific entries underlying its concerns and is effectively forcing credit unions to conduct unnecessarily expensive, inefficient reviews of fully three years’ worth of HMDA data, some of which the CFPB has had for more than two years, in less than 30 days. Such a request is not only unrealistic but also incredibly burdensome.”

Baker called on the bureau to delay the deadline and give credit unions the specific HMDA LAR entries with concerns “to ensure credit unions have a reasonable opportunity to review the CFPB’s concerns and, if necessary, resubmit their 2020, 2021, and 2022 HMDA LARs.”

NAFCU will continue to engage the bureau on this issue and keep credit unions informed of any updates. Monday’s Compliance Blog post provides additional details on the notices.