Credit Union National Association, December 19, 2022, Sudden HMDA rule changes require reasonable transition period
Credit unions and other financial institutions need a reasonable transition period to comply with sudden changes in the 2020 Home Mortgage Disclosure Act (HMDA) final rule, CUNA and other trades wrote to Federal Financial Institution Examination Council member agencies. CUNA’s Compliance team brought attention to a decision from the U.S. District Court for the District of Columbia—National Community Reinvestment Coalition v. Consumer Financial Protection Bureau—vacates portions of the 2020 HMDA final rule.
The letter notes small volume lenders report they cannot accomplish the required tasks in the final two weeks of the year, and that “pipeline” issues involving 2022 applications that do not receive final action until 2023 are concerning.
