The proposed policy guidance describes the loan-level HMDA data that the bureau would like to make available to the public beginning in 2019.
While the bureau proposes to make the bulk of this information public, there are some modifications to protect consumers’ privacy. For example, certain data fields would be excluded, such as the property address and applicant’s credit score. Also, certain information would be disclosed with less precision, like the applicant’s age – which would be reported as a range rather than a specific number.
FSR’s Housing Policy Council (HPC) sent a letter to the bureau asking it instead to rescind the guidance and follow the notice-and-comment rulemaking process.
“Securing sensitive consumer data is a top priority for the financial industry,” Ed DeMarco, president of FSR’s HPC, said. “The bureau’s desire to expand public reporting of sensitive loan-level data raises major security concerns and opens the door for reverse-engineering of data to harm consumer privacy.”
FSR said the CFPB’s new data submission process raises concerns about accessibility, functionality, data aggregation and storage, and culpability. In the letter, FSR and the trade associations offered some fixes, including providing the ability to submit data incrementally and permitting the appending of earlier data.
Finally, the groups asked the CFPB to start a public education initiative so consumers understand why lenders ask for certain information and why they must submit that information to the CFPB.
With the new acting CFPB director Mick Mulvaney in place, FSR is hopeful that the bureau will reconsider the guidance and follow a formal rule-making process.