Don't Like HMDA?

If you don't like HMDA - especially the new provisions - you should have written a comment letter. Comment letters do make a difference. The FRB received 300 comment letters, including letters from consumers and consumer organizations who argued for the changes.

Consumers argued against the burden concerns raised by financial institutions, stating that the reprogramming required to compile and report additional data is merely a one-time cost. These consumer advocates expect to use the HOEPA status indicator as a surrogate indicator for sub-prime loans.

Assuming that there are approximately 10,000 institutions and that at least several of the comments were from consumers, that leaves about 9,700 banks that didn't comment. The opportunity is lost. Now we have to concentrate on compliance.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 1, 2/02