July 25, 2008

To the Editor:

Expanding national data disclosure requirements to nonmortgage lending will spark controversy, certainly, but it holds the potential to swing open the doors of opportunity for millions of consumers ["Democrats Eyeing HMDA-Like Rules for Nonmortgages," July 18, page 3].

But given the tens of millions of households that lack even a basic bank account, why not extend the same transparency requirements to services?

Without a doubt, a new financial services disclosure act, enacted by Congress and incorporating what has worked in the Home Mortgage Disclosure Act, is sorely needed. Most nonmortgage lending data is still collected by myriad state agencies. Tracking foreclosures, certainly a national concern, is still a strictly local affair.

But perhaps most troubling is the fact that data collected by federal regulators on basic banking products and services is incomplete, inconsistent, and inaccessible to the public. In the past carefully crafted data disclosure requirements have proven invaluable.

Pricing information added to federal mortgage data in 2004 proved the existence of a two-tiered credit system, where consumers in minority markets pay more to borrow.

But without congressional action, there can be no similar data to root out unequal access to basic banking services.

Even before a mortgage decision is made, the availability of these other products and services will determine who can own a home and at what price.

Checking and savings accounts, insurance and retirement vehicles – barriers to any of these products may stifle a consumer’s financial future.

We applaud Chairman Frank’s commitment to dragging data on nonmortgage lending out in the open and respectfully request that financial services data not get left in the dark.

Dory Rand
Woodstock Institute


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