---
title: Online Bankers Training - Don’t Forget to Comment on HMDA!
description: BCC offers online banking regulations training & consulting - Don’t Forget to Comment on HMDA!
---

[Banker's Compliance Consulting Blog ](https://blog.bankerscompliance.com/en)

# [Online Bankers Training - Don’t Forget to Comment on HMDA!](https://blog.bankerscompliance.com/en/dont-forget-to-comment-on-hmda)

 Written by [David Dickinson](https://blog.bankerscompliance.com/en/author/david-dickinson) | Sep 16, 2019 11:40:14 AM

On May 3rd, we [alerted you](https://www.bankerscompliance.com/proposed-hmda-changesp/) to an [Advance Notice of Proposed Rulemaking (ANPR)](https://files.consumerfinance.gov/f/documents/cfpb_anpr_home-mortgage-disclosure-regulation-c-data-points-and-coverage.pdf) seeking comment on whether any changes should be made to [existing HMDA data fields](https://www.bankerscompliance.com/regulations-we-cover/home-mortgage-disclosure-act/).

**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](https://store.bankerscompliance.com/#/product/7beb48b7-6e90-43a5-acf0-5d4304c5335b?searchFilter.keyword=) 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](https://files.consumerfinance.gov/f/documents/cfpb_anpr_hmda-comment-period-extension.pdf) they were extending the deadline.  Comments must now be [submitted to the CFPB](https://www.regulations.gov/document?D=CFPB-2019-0020-0021) by October 15th.

Additionally, the CFPB [announced](https://files.consumerfinance.gov/f/documents/cfpb_nprm-hmda-regulation-c-comment-reopening.pdf) 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](https://store.bankerscompliance.com/#/product/7beb48b7-6e90-43a5-acf0-5d4304c5335b?searchFilter.keyword=).  Comments must now be [submitted to the CFPB](https://www.regulations.gov/document?D=CFPB-2019-0021-0369) by October 15th.

Get your comments in today!

**[HMDA TRAINING](https://store.bankerscompliance.com/#?keyword=HMDA&type=)**

Published  
2019/09/16

[View full post](https://blog.bankerscompliance.com/en/dont-forget-to-comment-on-hmda)

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