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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.

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