Federal Register Comments

HAC Shares DRAFT HMDA Comments

The Housing Assistance Council (HAC) is making available its DRAFT comments on the proposed amendments to the Home Mortgage Disclosure Act (HMDA); Docket No. CFPB-2014-0019 – RIN 3170-AA10.

The Bureau of Consumer Financial Protection (CFPB)published for public comment a proposed rule amending Regulation C to implement amendments to the Home Mortgage Disclosure Act (HMDA) made by section 1094 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

Congress enacted HMDA in 1975 as a way of protecting communities that may be denied access to credit markets. The law requires most depository and certain non-depository institutions to collect and publically disclose information on home loan applications and purchases. Thus, HMDA serves an important purpose in providing information on home lending activities, making it possible for the public at-large to identify potential areas of disinvestment and discrimination.

While the CFPB presents a substantial number of changes and enhancements to HMDA in the proposed rule, HAC’s comments focus on two primary issues that are of great importance and consequence to rural borrowers and consumers of home mortgage financial products: 1) the revised scope of HMDA reporting requirements; and 2) enhanced reporting and data collection for manufactured home loans. The Housing Assistance Council also provides general comments on issues related to new and enhanced data collection for underwriting and mortgage loan characteristics. These issues directly impact HMDA’s ability to provide useful information for rural America’s home lending markets.