HAC's Recommendations to the CFPB on HMDA Rule Assessment

HAC submitted comments in response to the Consumer Financial Protection Bureau’s (CFPB) Request for Information regarding the Home Mortgage Disclosure Act (HMDA) Rule Assessment. HAC and our rural stakeholders have relied on HMDA data for decades to improve our understanding of rural mortgage markets. The CFPB will use these stakeholder comments to help better evaluate the effectiveness of these changes in meeting the purposes and objectives of Title X of the Dodd-Frank Act.

Key takeaways:

Reporting Threshold
HAC strongly urges the CFPB to return to the 25-origination reporting threshold, for closed-end loans, as opposed to the new 100-origination threshold, in order to more accurately capture rural markets that are disproportionately served by small financial institutions.
Reliability Index
HAC Recommends that the CFPB resource and publish a HMDA “Reliability Index.” While not a fix for overly limited reporting thresholds, the development of an indicator would be helpful for the CFPB, data users, and consumers.
Additional Data
HAC applauds increased HMDA data reporting, but additional data and reporting are still needed. While the new housing data points – specifically those on manufactured housing – enhance the HMDA data usefulness, more data could improve an understanding of certain underserved markets. This is particularly true when it comes to tribal lands and specific loan programs.
Data Browser
HAC applauds CFPB’s HMDA data browser, which offers improved access to HMDA data over previous interfaces.

Policy
Shawn Poynter / There Is More Work To Be Done

HAC’s Recommendations to the CFPB on HMDA Rule Assessment

Key takeaways:

Reporting Threshold

Reliability Index

Additional Data

Data Browser

GET THE HAC NEWS!

50 Years for Rural America

Policy Shawn Poynter / There Is More Work To Be Done

Key takeaways:

GET THE HAC NEWS!

50 Years for Rural America

Policy
Shawn Poynter / There Is More Work To Be Done