Survey Number 2019-10

The Bureau of Consumer Financial Protection (“CFPB”) has issued an Advance Notice of Proposed Rulemaking (“ANPR”) relative to HMDA data points.

The Association has been engaged with the CFPB on the HMDA Rule since these changes were first proposed, and seeks your input in order to provide additional comments to the Bureau reflective of member views. This ANPR represents another meaningful opportunity to provide detailed comments and suggestions for change.

The stated purpose of the ANPR is to solicit input on whether to make changes to the data points that the 2015 HMDA Rule added to or revised in Regulation C. Additionally, the CFPB is soliciting comments relating to the requirement that institutions report certain business or commercial-purpose transactions made to a non-natural person and secured by a multifamily dwelling under Regulation C.

Your credit union first reported data under the new HMDA rule on March 1 of this year. This survey seeks data on the costs and other information from this experience. Unlike other surveys which seek your policy goals, the goal of this survey is to collect data reflective of your operational experience under the rule.

The full ANPR can be read HERE.

Please take a few minutes to complete the Association’s survey. This survey should take no more than fifteen (15) minutes of your time. The deadline to respond to this survey is Friday July 5. 

If you have any questions, would like to provide more additional comments to the Association, please email govaff-reg@ccua.org.

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* Contact Information

Below is a table that lists the data points that the CFPB added or revised to require additional information pursuant to the 2015 HMDA Rule.

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1. Please identify any new data point or any data point revised to require additional information from the table above for which the cost of collecting and reporting the information does not justify the benefit that the information collected and reported provides in furthering the purposes of HMDA.

For each such data point:

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* a. Please describe the nature and magnitude of any operational challenges in collecting and reporting the required information.

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* b. What ongoing costs are incurred in collecting and reporting the required information?

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* c. Has the Bureau’s new web- based data submission and edit-check system affected ongoing costs of collecting and reporting the required information? If so, how and how much?

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* d. To what extent are the data point’s requirements aligned with industry standards, and how does that affect ongoing costs of collecting and reporting the required information?

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* e. Would financial institutions generally collect the required information in the ordinary course of business absent Regulation C requirements?

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* f. If so, what are the incremental costs assoicated with reporting the required information?
  If not, what are the costs associated with collecting and reporting the required information?

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* g. How much value does the data point provide in furthering the purposes of HMDA?

2. The 2015 HMDA Rule requires financial institutions to complete free- form text fields for certain data points when certain circumstances are met.

For each free-form text field required by the 2015 HMDA Rule: 

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* a. What are the costs of providing information through the free-form text field?

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* b. What are the benefits of providing information through the free-form text field?

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* c. Are there better alternatives to providing information than through the free-form text field?

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* 3. Are there other considerations the Bureau should take into account in deciding whether to propose to eliminate or revise any new data point or revised data point from the 2015 HMDA Rule?

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* 4. Are there new or revised data points under the 2015 HMDA Rule for which more explanation is needed to clarify the collection and reporting requirements?

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* If YES, please identify any data point for which additional clarity could reduce the costs associated with collecting and reporting the data and improve the value of the data in furthering the purposes of HMDA.

The Bureau seeks to assess the extent to which requiring reporting of information on business- or commercial- purpose loans made to a non-natural person and secured by a multifamily dwelling imposes burdens on financial institutions and furthers HMDA’s purposes.

The Bureau seeks information that might assist the Bureau in deciding whether to propose to exclude such transactions from HMDA’s requirements.

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* 5. What is the value that data on such transactions provides for HMDA’s purposes?

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* 6. Please estimate the burden imposed by the requirement to report data on such transactions.

THANK YOU FOR TAKING THE TIME TO COMPLETE THIS SURVEY BY JULY 5, 2019. 
Please send any questions or comments to govaff-reg@ccua.org.

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