CUNA letter of support for the “Home Mortgage Disclosure Adjustment Act”
WASHINGTON, DC (March 22, 2016) —
The Honorable Tom Emmer House of Representatives Washington, DC 20515
Dear Representative Emmer:
On behalf of the Credit Union National Association (CUNA), I am writing in support of your legislation, the “Home Mortgage Disclosure Adjustment Act.” CUNA represents America’s credit unions and their more than 100 million members.
The Consumer Financial Protection Bureau (CFPB) recently finalized amendments to Regulation C that would significantly increase the amount of data mortgage lenders, including credit unions, will have to provide. The Bureau will now require credit unions that have originated 25 or more closed-end mortgage loans in the prior year to report dozens of data points in addition to what is required under the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. Further, the Bureau has extended these reporting requirements to home equity lines of credit.
These requirements impose significant burdens on credit unions beyond what Congress envisioned when enacting the Dodd-Frank Act. Credit unions will undertake significant expense to bring their systems into compliance with a rule that does very little – if anything – to provide credit union members with additional protection. This proposal will undoubtedly add to the compliance costs credit unions must pay – a cost that was $7.2 billion in 2014 – and will lead to mortgage credit and other credit union services being that much more expensive and possibly less available.
Your legislation would raise the threshold that triggers these reporting requirements to 100 closed-end and 200 open-end mortgages. This would provide much needed relief, particularly to smaller credit unions, which is why we strongly support the legislation.
On behalf of America’s credit unions, thank you very much for sponsoring this legislation. We look forward to continuing to work with you as this legislation moves forward, and appreciate your efforts to find meaningful regulatory relief for credit unions and their members.
Sincerely,
Jim Nussle, President & CEO
About CUNA
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 135 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit cuna.org. To find your nearest credit union, visit YourMoneyFurther.com.
