CUNA CompBlog: CFPB Proposes Amendments to the Regulation B Data Collection Requirements

On March 24th, the Consumer Financial Protection Bureau ("CFPB") issued a proposed rule to amend the monitoring information data collection requirements found in Sections 1002.5 and 1002.13 of Regulation B ("ECOA"). The primary purpose of the proposal is to better align the data collection requirements of ECOA with the previously amended data collection requirements of Regulation C ("HMDA").  

Background 
In October 2015, the CFPB finalized amendments to HMDA pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Among these is a requirement that applicants be permitted to provide monitoring information in a dis-aggregated format instead of the current aggregated format.  

There is a similar data collection requirement under ECOA. It requires the collection of monitoring information on applications for the purchase or refinance of a principal residence.  

The proposed rule attempts to provide clarification of and consistency between the separate data collection requirements of HMDA and ECOA. 

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