In a July 31, 2017 comment letter, CBAI again urged the CFPB to provide community banks with HMDA reporting relief. The letter was sent in response to the Bureau’s proposal to temporarily increase the transaction threshold to 500 lines of credit for two years and during that time reconsider the open-ended transaction coverage limits. CBAI renewed the recommendations made in its May of 2015 comment letter to the CFPB which specifically included permanently increasing the open-end line of credit reporting threshold to 2,000 (versus the temporary proposed 500) lines of credit.
CBAI also expressed concern with the Bureau’s rulemaking process which has only provided few and minor exemptions for community banks after voluminous and complex rulemaking, which in itself constitutes an unnecessary and additional regulatory burden on community banks. CBAI urged the Bureau to use its authority granted under the Dodd-Frank Section 1022(b)(3)(A) which recognizes the need to tailor regulations to fit the diversity of the financial marketplace, and explicitly gives the CFPB the authority to adapt regulation by allowing it to exempt any class of entity from its rulemaking. Community banks do not abuse their customers and communities and are deserving of the broad exemptions the Bureau is able to grant them under the law. Read Comment Letter.