ICBA is urging community banks to submit comment letters in support of the Consumer Financial Protection Bureau’s (CFPB’s) proposal to raise the coverage thresholds for collecting and reporting data about closed-end mortgage loans under the Home Mortgage Disclosure Act to 100 loans. You can do this by visiting ICBA’s “Be Heard” Grassroots Action Center.
Tell the CFPB that increasing the threshold will help offset the significant cost and time required for smaller institutions to collect and report HMDA data. The sample comment letter provided also urges the CFPB to make permanent the 500 open-end lines of credit threshold instead of reverting back to 200 in 2022 as such loans continue to be profitable and indispensable products for customers. As ICBA notes: This is a once-in-a-generation opportunity to get a complete exemption from collecting and reporting HMDA data for smaller institutions.