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Joint Trades Letter - HMDA Resubmission
March 14, 2016
Office of the Executive Secretary
Bureau of Consumer Financial Protection
1700 G Street NW.
Washington, DC 20552
RE: Request for Information Regarding Home Mortgage Disclosure Act
Resubmission Guidelines; Docket No. CFPB-2015-0058
Dear Ms. Jackson,
The Consumer Bankers Association1 and the American Bankers Association2 (collectively, the Associations) appreciate the opportunity to respond to the Bureau of Consumer Financial Protection (Bureau) Request for Information (RFI) Regarding the Home Mortgage Disclosure Act (HMDA) Resubmission Guidelines (Resubmission Guidelines).3
Since 1994 when HMDA’s implementing regulation, Regulation C, was amended to address data accuracy,4 our members have maintained strict compliance procedures and some institutions have dedicated entire departments within the bank to ensuring and improving the accuracy of HMDA data. Despite our members’ best efforts, however, the complexity of HMDA fields and the inevitability of human and technological error make it impossible for the data to be 100% accurate.
As the Bureau considers updating its Resubmission Guidelines, it is important to keep in mind the breadth of mortgage providers and the wide range of mortgage products they offer to meet consumers’ home finance needs. Guidelines that are too restrictive or that do not take into account that variety will constrain the availability of both products and providers, undermining the industry’s ability to serve the credit needs of borrowers, particularly less qualified applicants...(continue reading)