Comment on CFPB-2011-0020-0001

1. I recommend a higher threshold for HMDA applicability than 1 home purchase or refinance loan, for example, 5 or more. 2. I recommend a higher threshold for enforcement action for HMDA errors than the current regulatory guideline of 5%, particularly for depository institutions with relatively small number of entries (say, 30 or less). 3. I recommend more guidance on the "preapproval" program. Currently some regulators include "Committment letters" (following FULL application, in the definition). I think the information about pre-approvals is overly burdenson (many institutions no longer offer preapprovals because of the HMDA regulatory burden). 4. I recommend HMDA LARs be considered accurate if reported data is within accurate "ranges". For example, so long as the reported income remains within the actual income with respect to the income category for that census tract (i.e. low, moderate, middle, upper), the entry should be consdered accurate. Income should also be allowed to be stated as NA for business purpose loans (not just loans to businesses), where the property's cash flow is the "income" being considered. Alternatively, additional guidance is necessary to agree "Gross annual income" to business or property revenue/cash flows. 5. Another field that causes high regulatory burden is "application received". The process of making an "application" along with the differing definitions of "application" between Reg B, RESPA, Reg Z, and HMDA, make a specific date difficult to pin down. Again, accuracy with ranges would severly reduce this range (say, within 10 days of the date that a reviewing examiner might consider a better "application received" date.)