Six leading industry trade groups have submitted a letter commenting on the CFPB’s proposed rule amending Regulation C to expand Home Mortgage Disclosure Act data reporting requirements.  The trade groups consist of the Consumer Bankers Association, Mortgage Bankers Association, American Bankers Association, Consumer Mortgage Coalition, Financial Services Roundtable and Housing Policy Council.

In the letter, the trade groups question the CFPB’s proposal to add various new data fields, including automated underwriting recommendations, borrower paid origination charges, total points and fees, total discount points, interest rate, prepayment penalty, QM status and HELOC first draw amount.  The trade groups ask the CFPB to weigh the consequences and value of adding the new fields.

The trade groups also urge the CFPB:

  • Not to extend the scope of Regulation C to require reporting of commercial and other loans that are for purposes other than home mortgage financing
  • To keep all additional data collected under the proposal private pending promulgation of privacy and data security rules to protect the confidentiality of HMDA data
  • To adopt a reasonable implementation schedule and not require HMDA reporting under a new rule earlier than 24 months after the January 1st following issuance of a final rule
  • To codify data integrity standards with reasonable tolerances either in Regulation C or authoritative guidance
  • To adopt a higher reporting threshold of at least 250 home mortgage financing transactions each year for both depository and non-depository institutions
  • To conform Regulation C with related mortgage regulations and industry standards, and
  • To coordinate with the prudential regulators before making changes that may affect CRA reporting.