CBA: CFPB Should Not Publicly Release New HMDA Data Exposing Consumers to Privacy and Fraud Risks

November 24, 2017

Washington, D.C. – The Consumer Bankers Association (CBA), along with four other trades, today urged the Consumer Financial Protection Bureau (CFPB) to alter the way the agency reports loan-level HMDA data to prevent the public release of individual consumers’ HMDA data and unnecessary exposure to increased privacy risks, identity theft and fraud. In order to protect consumers from harm, the letter urges the CFPB to report the new HMDA data in the aggregate and ensure processes are in place to protect the interests of individual consumers.

In the letter, CBA’s Senior Counsel Anastasia Stull and the other trades jointly write:

“The CFPB’s balancing test fails to consider real threats to consumers, as re-identification under the Proposed Guidance would be a virtual certainty. Research has shown that re-identification is already highly possible, even using only the current public HMDA data. It becomes significantly more attainable with any increase in data disclosures lacking sufficient masking. With advances in technology enabling easier re-identification, this concern transforms from a risk to a virtual certainty. To guard against invasions of privacy, identity theft, and fraud, CFPB should disclose the new data only in aggregate form, carefully designed to protect the financial interests of individual consumers.”

You may read the full letter here.


About the Consumer Bankers Association

The Consumer Bankers Association represents America’s retail banks above $10 billion in assets. We advance legislation and promote policies geared toward creating a stronger industry and economy. Established in 1919, CBA’s corporate member institutions account for 1.6 million jobs in America, extend roughly $3 trillion in consumer loans, and provide $270 billion in small business loans. Follow us on Twitter @consumerbankers.