On May 25, 2017, WBA submitted a comment letter regarding CFPB’s proposed amendments to the 2015 HMDA final rule. WBA supported most of the amendments, as they provide clarification. Additionally, WBA advocated for voluntary reporting open-end lines of credit and applications for open-end lines of credit that are excluded transactions because the financial institution originated fewer than 100 open-end lines of credit in either of the two preceding calendar years, as WBA believes it is important to memorialize such language in the official text, as opposed to the commentary. WBA opposed adding comments regarding multifamily dwellings, as it is our belief that a loan secured by five or more separate dwellings in more than one location does not meet the final rule’s definition of multifamily dwelling. Click here to view the proposed revisions.
Click here to read the full WBA comment letter.