HMDA, fair lending and the CFPBFor more than 25 years, credit unions that provide mortgages to their members have been responsible for filing data about the consumers. This data, required by the Home Mortgage Disclosure Act, was intended to determine lending patterns and, where applicable, identify those lenders who were inadvertently or overtly discriminating based on race, sex and national origin.

After the initial concerns and issues were addressed, credit unions became adept at preparing this data and sending it off to the Federal Financial Institutions Examination Council. After delivery, there was typically no response from the FFIEC unless they required a resubmission. It got to the point that we became rather blasé about the whole thing. In others words, it became a ho-hum kind of exercise that we went through each year.

Now however, there has been a significant change. The responsibility for this data collection and analysis has been moved to the CFPB. This organization has let it be known that it is no longer simply collecting data. In fact, it has already announced that it is expanding the amount of data to be reported in 2019, and is very actively working on various ways to analyze the results. While we are not exactly sure what this will mean, we have a clue from lenders who have been examined. Their experience tells us that the CFPB will be taking a very hard stance on both the quality of the data as well as what its analysis is saying about us as lenders.

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