By Brian D. Godwin
On July 24th of this year, the Consumer Financial Protection Bureau (CFPB) published a proposed rule related to the Home Mortgage Disclosure Act (HMDA). The rule is intended to improve the information reported about the residential mortgage market. Many of the proposed changes were mandated by the Dodd-Frank Act, while some of them arose from liberties taken by the CFPB.
It would be difficult to foresee a final rule having an effective date prior to January 1, 2016. That’s because the rule would need to be effective at the beginning of a year, and a 2015 effective date would not allow for a sufficient implementation period.
Focusing on tomorrow, let alone a year and a half from now can be quite a challenge for credit unions as they find themselves very busy in service to their members. However, by spending time today, looking at the proposed rule and providing comments to the CFPB, credit unions can make life a bit easier in the months and years to come.
While the CFPB can anticipate the manner in which proposed rules may affect credit unions, it cannot have a full understanding of each credit union’s operations, nor how a proposed rule might impact that credit union. Providing that kind of input can help shape final rules.