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HMDA and CDD Comments Due in January, FOM in February
Tuesday, January 5, 2016 6:50 AM

Comments on Home Mortgage Disclosure Act (HMDA) data collection and customer due-diligence (CDD) rules are due in January, and comments on the National Credit Union Administration’s field-of-membership proposal are due in early February.

The NCUA’s proposal would make revisions to the agency’s field of membership rules, which would allow credit unions more flexibility to serve those that share a common bond.

CUNA has prepared a detailed summary of the proposal, designed to help credit unions to examine the proposed rule and determine how it would impact them. CUNA issued an action alert in December, urging credit unions to submit a large number of formal comment letters to the NCUA reflecting league and credit union positions on the proposal.

Bankers have already made efforts to oppose the proposal, making it very important credit unions have a strong united voice in support of the proposed changes, so it's vital that credit unions send their comments to the agency before the deadline.

Comments on the NCUA’s field-of-membership proposal can be sent to the NCUA by Feb. 8.

Comments due this month include:

  • Jan. 11: Consumer Financial Protection Bureau request to renew the Office of Management and Budget approval for existing information collection. Comments are requested on whether the collection of information is necessary, the accuracy of the CFPB’s estimate of burden of the collection, ways to enhance the information being collection and ways to minimize the burden of information collection; and
  • Jan. 25: U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) assessment and initial regulatory analysis of its customer due diligence (CDD) proposal. FinCEN published a Regulatory Impact Assessment and Initial Regulatory Flexibility Analysis in December on its August 2014 CDD proposal. CUNA is seeking impact on the accuracy of FinCEN-determined compliance costs, as well as the requirements in the CDD proposal. Comments are due to CUNA by Jan. 11. 

Please refer to Cornerstone's Regulatory Grid Summary or CUNA's Comment Calls page for more details about this proposal and writing your comment letter. If you need help in crafting your own letters, or if you have questions, please contact Cornerstone Credit Union League SVP Regulatory Compliance Suzanne Yashewski at or 512-853-8516.