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CUNA HMDA should only apply to large lenders
WASHINGTON (8/24/10)--The Credit Union National Association (CUNA) has said that while it does not advocate that specific, additional information be reported under the Home Mortgage Disclosure Act (HMDA), it agrees with a recent suggestion that the new HMDA reporting requirements apply “only to the largest mortgage lenders that make the vast majority of mortgage loans.” Such a plan would initially exclude credit unions and small community banks, but could be expanded as needed, CUNA said. CUNA recommended that the Federal Reserve take a “bright line” approach to HMDA reporting, limiting the need for HMDA reports to situations in which there is a lien on a given home. The Fed is considering whether certain data elements of HMDA should be added, modified, or deleted, and is holding a series of hearings to collect input from interested parties. CUNA in a comment letter filed to the Fed last week said that credit unions could support additional changes to the HMDA requirements if the Fed or the to-be-established Consumer Financial Protection Bureau (CFPB) “clearly demonstrates that the new information would further the goal of ensuring fair lending and anti-discriminatory practices” while minimizing the reporting burden on credit unions. CUNA said it opposes portions of HMDA that would require credit unions to disclose the existence of existing home equity lines of credit and to report the total income and credit scores of potential mortgage-holders. It also recommended that HMDA reporting requirements related to loan pre-approvals, unsecured home improvement loans, and whether the home is a manufactured home be removed from the final rules. The association also encouraged the Fed to hold additional meetings with affected financial institutions as the HMDA rulemaking process moves forward, and to give credit unions at least two years to adapt to the new HMDA requirements once they are imposed. For the full comment letter, use the resource link.


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