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CUNA Backs Bill Raising HMDA Reporting Requirements Threshold
Tuesday, March 22, 2016 6:40 AM

Legislation to raise the threshold for Home Mortgage Disclosure Act (HMDA) reporting requirements for small institutions, including many credit unions, has the full support of the Credit Union National Association. Jim Nussle, CUNA president/CEO, wrote to Rep. Tom Emmer (R-MN) Monday in support of his Home Mortgage Disclosure Adjustment Act.

Emmer’s bill would raise the threshold that triggers HMDA reporting requirements to 100 closed-end and 300 open-end mortgages, up from the current threshold of 25 or more closed-end mortgage loans.

“This would provide much needed relief, particularly to smaller credit unions, which is why we strongly support the legislation,” Nussle wrote.

The Consumer Financial Protection Bureau finalized new HMDA reporting requirements in October 2015, significantly increasing the amount of data that mortgage lenders will have to provide. The CFPB’s rule calls for many more data points than are required by Dodd-Frank, and the CFPB also extended these reporting requirements for home equity lines of credit.

“These requirements impose significant burdens on credit unions beyond what Congress envisioned when enacting the Dodd-Frank Act. Credit unions will undertake significant expense to bring their systems into compliance with a rule that does very little—if anything—to provide credit union members with additional protection,” Nussle wrote. “This proposal will undoubtedly add to the compliance costs credit unions must pay—a cost that was $7.2 billion in 2014—and will lead to mortgage credit and other credit union services being that much more expensive and possibly less available.

Nussle’s $7.2 billion figure comes from the comprehensive regulatory burden study CUNA conducted with Cornerstone Advisors, and is now available in full.