If not, you might not be alone.
A trade group representing credit unions says it would helpful to get a bit more time.
The National Association of Federally-Insured Credit Unions CEO Dan Berger today sent a letter to Consumer Financial Protection Bureau Interim Director Mick Mulvaney requesting that the bureau delay the effective date of the HMDA final rule.
This would allow a voluntary compliance period and execute a "good faith efforts" policy for examinations, the letter states.
Under current law, depository institutions are required to collect and periodically report to federal financial regulatory agencies information related to the number and dollar value of closed-end loans and open-end lines of credit that those institutions originate or purchase each year.
The primary federal authority being the CFPB, which currently exempts some institutions from reporting information about closed-end loans or open-end lines of credit if the number of loans or accounts is below a threshold for each type of credit instrument.
"NAFCU and our members support the intended purpose of HMDA, which is the promotion of fair lending and ensuring equitable access to credit in the housing market," Berger said in the letter. "However, throughout the rulemaking process, NAFCU and our members have expressed concerns regarding the Bureau's significant expansion of HMDA. As currently drafted, the HMDA rulemaking has and will likely continue to have a substantial role in increasing the overwhelming costs associated with regulatory compliance, which is taxing credit unions' finite resources."
Either way, the changes aren't expected to cost taxpayers dearly. Using information from CFPB, the Congressional Budget Office estimates that enacting the HMDA updates would cost the agency $1 million over the 2018-2027 period to complete a rulemaking and update its data collection systems.