On March 26, 2020, the CFPB issued a press release that it is providing flexibility for financial companies during the pandemic period, suspending some data collection requirements so that lenders may focus on assisting customers in need. Data suspensions include quarterly HMDA data reporting, information on credit card and prepaid accounts, cost of compliance with Dodd-Frank Section 1071 survey data, and information on PACE financing.
To support the announcement, the CFPB issued three policy statements that specify the CFPB will not cite a financial institution during an examination or initiate an enforcement action for failure to submit information covered by the statements as otherwise required under law. The CFPB reminds entities to continue to collect subject data for reporting at a later time which will be determined and announced by the CFPB when available.
In addition to the policy statements, the CFPB also indicated that it would provide additional flexibility in scheduling any new examinations of financial institutions, as well as in issuing other supervisory activities, so as to minimize disruption and consider an institution’s good faith efforts to assist consumers during the pandemic period.
The Bureau issued the following policy statements to support their current position:
Statement on Supervisory and Enforcement Practices Regarding Quarterly Reporting Under the Home Mortgage Disclosure Act
Statement on Supervisory and Enforcement Practices Regarding Bureau Information Collections for Credit Card and Prepaid Account Issuers
Statement on Bureau Supervisory and Enforcement Response to COVID-19 Pandemic