In a letter to the Consumer Financial Protection Bureau today, the American Bankers Association shared a number of concerns bankers have raised recently about complying with the bureau’s expanded Home Mortgage Disclosure Act data collection requirements. The letter followed a recent meeting between ABA and CFPB staff.
ABA noted that it continues to receive questions from member bankers about the new HMDA data fields that cannot be definitively answered by relying on the regulation or the bureau’s existing HMDA resources. Under these circumstances, ABA noted that “it can be expected that lenders acting reasonably and in good faith will make different interpretations, resulting in inconsistencies in how the data is reported for many of the fields.”
ABA urged the bureau to consider these lingering challenges and uncertainties when determining whether to disclose HMDA data publicly in 2019. The association also reiterated previous concerns about the CFPB’s failure to engage in a formal rulemaking to address privacy issues presented by the public disclosure of HMDA data.