On October 15, BPI joined the American Bankers Association, Consumer Bankers Association, Housing Policy Council, and Mortgage Bankers Association in a letter responding to the CFPB’s advance notice of proposed rulemaking seeking feedback on the costs and benefits of the expanded data reporting requirements associated with the CFPB’s 2015 final rule under the Home Mortgage Disclosure Act (HMDA). Citing data from a survey of mortgage lenders, the letter highlights the significant cost of compliance with the requirements of the 2015 rule and identifies a number of data points whose informational benefit is outweighed by the burden of collection, maintenance, and reporting.
BPI also joined the American Bankers Association and Mortgage Bankers Association in a separate letter echoing the point that business-to-business multifamily loans should be exempt from HMDA reporting requirements.