CBA Submits HMDA Comment Letter to CFPB

October 29, 2014

Washington, D.C. (October 29, 2014) – Today, the Consumer Bankers Association (CBA) and other financial trade associations submitted a letter to the CFPB in response to their request for comment on proposed amendments to Regulation C to implement amendments to Home Mortgage Disclosure Act (HMDA).

While the joint trades support the purpose of HMDA -- to provide information on the availability of credit in the home mortgage market – they are concerned that the CFPB’s proposal to markedly increase HMDA data reporting and coverage goes beyond the law’s purposes in some areas and will unduly harm competition and increase costs in others. At the same time, the trades do not believe that the proposal adequately ensures consumers’ privacy and data protection, at a time where data breaches are occurring on a regular basis. If the proposal remains unchanged following the submission of comments, it will result in significant adverse and unintended consequences which would harm consumers and unduly increase costs.

The joint trades comment letter urges the CFPB to:


  • Weigh the consequences and value before adding fields;
  • Limit Regulation C’s coverage to only home mortgage loans;
  • Protect consumers from invasions of privacy and address data security concerns through rulemaking before the contents of the HMDA fields added by the Proposal are released to the public;
  • Establish a reasonable implementation schedule for these changes given that technology resources will be consumed by other demands, especially the TILA RESPA Integration through August 1, 2015 and beyond;
  • Establish workable data integrity standards for HMDA reporting considering the many new data points proposed to be collected and reported;
  • Minimize unnecessary reporting requirements to preserve credit options and avoid unnecessary costs;
  • Conform Regulation C to other rules and to MISMO as proposed; and
  • Coordinate with other regulators on the Community Reinvestment Act (“CRA”) implications of these changes.

The full joint comment letter can be found here.

About CBA

Founded in 1919, the Consumer Bankers Association (CBA) is the trade association for today's leaders in retail banking - banking services geared toward consumers and small businesses. The nation's largest financial institutions, as well as many regional banks, are CBA corporate members, collectively holding well over half of the industry's total assets. CBA’s mission is to preserve and promote the retail banking industry as it strives to fulfill the financial needs of the American consumer and small business.