October 11, 2019
Comment letter on Docket No. CFPB-2019-0021 or RIN 3170-AA76
AKPIRG opposes the proposal of the Consumer Financial Protection Bureau (CFPB) to exempt thousands of lending institutions from reporting Home Mortgage Disclosure Act (HMDA) data. The Alaska Public Interest Research Group (AKPIRG) is Alaska’s only statewide consumer advocacy non-profit. AKPIRG works to ensure that consumers rights are protected and they are treated equally. Part of our work includes teaching individuals how to raise their credit score through managing debt in collections, as well as alternatives to predatory, high-cost loans. These two factors have a major impact on a person’s credit score and can make it difficult or impossible to become a homeowner. As a member of the National Community Reinvestment Coalition (NCRC), we support NCRC’s detailed analysis and comments on this matter.
Congress passed HMDA in 1975. Lenders, including small volume lenders, have been collecting and reporting data for decades. Currently, if a lending institution makes 25 or fewer mortgage loans, it is not required to report HMDA data. We oppose the CFPB proposal to raise the threshold.
Likewise, the CFPB’s invitation for comments on even higher thresholds does not make sense. Congress has already exempted lenders making less than 500 loans from reporting the more complex HMDA data requirement under Dodd Frank. They are required to report the data they have collected and submitted for decades!
The CFPB is also proposing to increase the threshold for reporting open-end lines of credit often called Home Equity Lines of Credit (HELOCs). Under the CFPB’s proposal to increase the threshold to 200 open-end lines of credit, far too many lenders and loans will escape the scrutiny of public review.
The mortgage data that comes out of HMDA has been as important a measure for the financial institutions themselves as it has been for advocates in ensuring non-discrimination in lending.
Veri di Suvero
Alaska Public Interest Research Group