Comment letter to the Consumer Financial Protection Bureau urging them to expand Home Mortgage Disclosure Act reporting requirements

This letter commends the Consumer Financial Protection Bureau (CFPB) for proposing rules that expand the reporting requirements for the Home Mortgage Disclosure Act (HMDA). The letter urges the CFPB to further strengthen the rules by separately reporting cash-out and rate- and term-refinances, requiring that lenders report data on the credit scores of borrowers to the CFPB and, including multifamily loans in the reporting requirements for depository institutions, and requiring existing and future HMDA data to include a Universal Loan Identification indicator that would potentially allow the data in the new performance and modification databases to be linked with HMDA data.