Don’t Forget to Comment on HMDA!

On May 3rd, we alerted you to an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on whether any changes should be made to existing HMDA data fields.

The ANPR specifically requests comment on the following:

1. Whether changes should be made to…any new data point or any data point revised to require additional information…for which the cost…does not justify the benefit…Specifically address any operational challenges, ongoing costs (including the impact of the CFPB’s new submission process), the value of the information from a HMDA perspective and whether the information would be regularly collected anyway;

2. Costs and benefits and proposed alternatives to free-form text fields;

3. If there are any other considerations to take into account in proposing whether to eliminate or revise any new or revised data; and,

4. If there are any new or revised data points for which more explanation is needed.  

Comments are also specifically requested on whether there is a benefit to reporting business loans to a non-natural person that are secured by a multifamily dwelling.  The CFPB seeks information on the following in relation to these types of loans:

5. The value of the data;

6. Other benefits; and,

7. The burden imposed.

If you have thoughts on these items, we strongly encourage you to submit your comments to the CFPB.  The CFPB does request that when responding to an issue, you indicate the number that we’ve provided above.  We’ve prepared a comment letter and have made it available in the Free Lending Tools on our website, not only to encourage you to comment but also to help guide you in the process.  Feel free to add to and/or revise it as you wish.

Comments were originally due by July 8th; however, the CFPB later announced they were extending the deadline.  Comments must now be submitted to the CFPB by October 15th.

Additionally, the CFPB announced their intent to reopen the comment period (which ended June 12th) regarding the permanent HMDA coverage thresholds for closed-end mortgage loans and open-end lines of credit, as well as the effective date for any change in the closed-end coverage threshold.  Since the comment period is being reopened, the CFPB does not look to finalize any change to the closed-end threshold by January 1st.  As a result, the CFPB is looking for comments on a mid-year effective date (e.g. May 2020) versus a January 1,2021, effective date.  Our comment letter for this proposal is also available in our Free Lending Tools.  Comments must now be submitted to the CFPB by October 15th.

Get your comments in today!



David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

Recent Posts

Understanding Customer Risk Profiles

Section 1071: Business Owner Status

Auditing Your BSA/AML Program