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AFSA Comments on HMDA Proposed Rule

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On Tuesday, October 15, the American Financial Services Association submitted a comment letter on the Consumer Financial Protection Bureau (CFPB)’s Advanced Notice of Proposed Rulemaking amending the October 2015 final rule on the Home Mortgage Disclosure Act (HMDA), noting that the Bureau should reduce the number of data points financial institutions must collect and report.

“AFSA members are committed to ensuring that all people have equal access to credit. As such, we support the spirit of HMDA and have invested heavily in compliance processes to ensure that the statute is fulfilled,” AFSA Vice President Celia Winslow wrote in the comment letter. “Enacted in 1975, HMDA sought to determine if potentially discriminatory practices in the area of mortgage lending were occurring. HMDA data is intended to provide information to address fair-lending concerns about loan pricing and to gain a better understanding of the mortgage market. That goal was met for over thirty years and can continue to be met with fewer data points.”

The letter outlines three key areas that will make HMDA data more focused and effective:

· The Bureau should limit the number of required data points. The housing disclosure act’s data points were added or updated in 2015. The burden of additional data collection, particularly on small lenders, should be considered, because …

· Increased regulation may drive small lenders out of the market. Many AFSA members are small- or medium-sized business that operate in communities and serve niche loan needs that bigger institutions do not meet. Additional data collection requirements will add overhead that discourages smaller lenders from offering offer mortgage loans, because …

· Additional data collection is costly, provides uncertain benefits and raises privacy concerns – The data requirements already on the books benefit prospective homebuyers, but it’s unclear what additional data points would accomplish, beyond adding costs and creating pools of data that raise privacy concerns for consumers and lenders alike.

AFSA Comments on HMDA Proposed Rule
Oct 15, 2019

On Tuesday, October 15, the American Financial Services Association submitted a comment letter on the Consumer Financial Protection Bureau (CFPB)’s Advanced Notice of Proposed Rulemaking amending the October 2015 final rule on… Read the rest

Gen Z: Your Future Customers & How to Reach Them
Oct 14, 2019

The AFSA Annual Meeting is next week and this is our last program update! Are you joining us in Nashville? There's still time to register and hear from Michael Marx, Senior Director of Reasearch and Insights at Visa on creating products Read the rest

CFPB Next to Get the House Financial Services Committee Treatment
Oct 11, 2019

On October 9, 2019, House Financial Services Chair Maxine Waters (D-CA) announced a new slate of committee hearings and markups. One notable session, scheduled for October 16, 2019, is entitled, “Who is Standing Up for Consumers? … Read the rest

Becerra Releases Proposed CCPA Regulations
Oct 10, 2019

Today, California Attorney General Xavier Becerra released the office’s long-awaited proposed regulations implementing the California Consumer Privacy Act (CCPA). AFSA previously submitted comments on behalf of its members,… Read the rest

AFSA Files Motion for Preliminary Injunction in NV Suit
Oct 09, 2019

Yesterday, AFSA filed a motion for a preliminary injunction in its lawsuit in federal court seeking to enjoin enforcement of the spousal credit history provisions of Nevada SB 311/Ch. 280. The motion is available here.

AFSA first filed suit… Read the rest

How Real-Time Payments Drive Satisfaction
Oct 08, 2019

Join us on October 17 at 2:00 p.m. ET for How Real-time Payments Drive Satisfaction, presented by ACI.

Are you ready for real-time payments? Is your strategy set?

Register today we discuss real-time payments and how they can instantly create

Read the rest

AFSA Annual Meeting Hot Topic: Cybersecurity
Oct 07, 2019

Sarah Bloom Raskin is one of the distinguished leaders of the financial services sector, having served as Deputy Treasury Secretary under President Obama from March of 2014 until January of 2017, as the highest-ranking woman in Treasury … Read the rest

AFSA Welcomes CFPB Deputy Director to Annual Meeting
Oct 02, 2019

The American Financial Services Association is pleased to welcome Brian Johnson to the 2019 AFSA Annual Meeting in Nashville.


Mr.Johnson currently serves as the deputy director of the Consumer Financial Protection Bureau (CFPB). Previously,Read the rest

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