CBAI Urges the CFPB to Increase HMDA Thresholds

In a June 11, 2019 comment letter, the Community Bankers Association on Illinois (CBAI) urged the Consumer Financial Protection Bureau to increase Home Mortgage Disclosure Act thresholds. CBAI highlighted its longstanding interest in HMDA and its consistent advocacy with the Bureau and Congress for higher exemption thresholds for community banks. Higher thresholds are especially important for the smallest institutions due to the cost and significant amount of time required for compliance, and they originate such few loans that their impact on national trends is insignificant. In addition, community banks serve their customers and communities fairly and with respect and do not practice the predatory and discriminatory lending practices that HMDA is designed to identify and prevent. While CBAI stated its support for the regulatory relief contained in this Proposal we urged the Bureau to more aggressively use its authority granted under the Dodd-Frank Act to tailor regulations to fit the diversity of the financial marketplace, and to exempt any class of entity from its rulemaking (e.g., community banks). Read CBAI Comment Letter.