“They laugh at me here, because I get so excited about data,” she said. “But the data tells me a lot, even finding a loan that was in the process for too long. The data speaks to me. To me it's fun.”

Her job is getting more fun, but it's the type of fun credit union executives and their trade groups criticize as another onerous regulatory burden.

More credit unions will have to report data to comply with the Home Mortgage Disclosure Act. The data points will become more numerous. And, for some, the reporting will come every three months, instead of annually.

Credit unions and other financial institutions must start capturing the new data by Jan. 1, 2018 and start reporting it by 2019.

HMDA was enacted in 1975 to prevent racial discrimination in lending. It has its roots in the Civil Rights movement and opposition to “redlining” practices that effectively choked off credit to African Americans and black neighborhoods.

The new rules were issued last September, and credit unions are now working on making changes so they will be able to comply. The CFPB, which is administering the rules for credit unions, has said it is developing a new HMDA collection system designed to reduce burdens in the submission process and ensure high data quality standards.

“We knew it was coming,” Vazquez said. “Most places are already collecting the data, but now you'll have to start reporting it. It's going to be burdensome for the smaller credit unions. It would be nice if they would give the smaller institutions a little bit more of a break.”

The rule applies to almost all credit unions that originate first lien mortgages or home equity lines of credit.

The rule also expands the coverage of HMDA reporting. Previously the rule applied only to lenders of closed-end mortgages. Now it also applies to those issuing more than 100 home equity lines of credit per year.

Some credit unions organize their HELOC business under consumer lending, which will complicate their compliance by requiring them to create dual systems.

“Mandating the HELOCs adds compliance costs, training issues,” Vazquez said. “Some of the systems that we have may not be able to support collecting that data. You're looking at system modifications.”

Leominster uses software called Fair Lending Wiz, which it licenses from Wolters Kluwer Financial Services.

“It's very expensive,” she said. “A lot of the smaller credit unions don't have the resources and expertise to proactively do Fair Lending analysis.”

By doing Fair Lending analysis on a regular basis, if the data were to show a high mortgage rejection rate for a particular group, the credit union can go back to study the issue in more detail to determine if it indicates the credit union should consider a first-time homebuyer program.

“It does help you to look at your portfolio to see where you're missing business opportunities as well,” she said.

Under the new rules, Vazquez and other Fair Lending disclosure officers will have to look at new factors, including age and more detailed classifications for race and ethnicity.

Race and ethnicity categories have been expanded so they match those set by the White House Office of Management and Budget for the 2010 Census.

Currently, credit unions and other lenders report whether applicants' ethnicities are Hispanic or non-Hispanic. Now they will be asked whether the applicant was Cuban, Mexican, Puerto Rican, South or Central American, or of other Spanish culture or origin.

Among races, Asian has been disaggregated so that applicants should be identified as Asian Indian, Chinese, Filipino, Japanese, Korean, Vietnamese or Other Asian.

The Native Hawaiian and Other Pacific Islander race has been disaggregated into four categories: Native Hawaiian, Guamanian or Chamorro, Samoan or Other Pacific Islander.

The other race categories are: White, Black or African American, American Indian or Alaska Native and Some Other Race.

A new Uniform Residential Loan Application has already been redesigned to plug in the new data points.

If lenders don't have their back-end systems ready for the new loan tracking process by 2018, they will have to use special addendum forms. Fannie Mae and Freddie Mac use different decision engines, so credit unions will have to design two types of addendums.

Credit unions will also have to redesign their user interfaces – both those for internal use and those for customers and brokers.

Credit unions have joined with banks and other lenders to push back against HMDA rules, which it considers another onerous regulatory expansion – a theme that resonates with the new Trump administration.

Is there any upside? The member organizations say no.

“It's pretty much pure regulatory burden,” Alexander Monterrubio, NAFCU's director of regulatory affairs, said. “We've generally seen a lot of credit unions add staff as a result of the HMDA rule. It's definitely an area credit unions have had to spend more money on.”

While the new HMDA requirements will add more data, it will still only allow regulators to flag financial institutions that warrant further examination for discriminatory lending. But it's not enough data to make that determination.

“It doesn't reflect how we're operating,” Andrew T. Price, CUNA's senior director of advocacy and counsel, said.

Price said the disclosures could attract opportunistic class action suits based on incomplete data. For example, lawyers might fish for credit unions that under-serve one group when another reason not included in the data, such of field of membership, would show a claim to be groundless.

However, that defense might only emerge in discovery, after the credit union has piled up heavy legal fees. In those situations, credit unions would have to weigh the costs and benefits of defending or settling. “You see a lot of cases that are frivolous,” Price said.

Trial lawyers aren't the only ones sifting through HMDA data.

Last November, the U.S. Supreme Court heard arguments on a case that could determine whether cities can sue banks under the Fair Housing Act for predatory lending that indirectly hurt the cities through foreclosures.

The case stemmed from a discriminatory mortgage lending practices suit brought by Miami against Bank of America and Wells Fargo in the wake of a wave of foreclosures after the 2008 financial crisis.

The case hinges on standing, which often requires showing economic harm. Robert S. Peck, a lawyer for the city, tried to tell the court how Miami suffered economic harm.

“The banks' practice of providing minority borrowers with more expensive and riskier loans than they qualified for, or that nonminority borrowers received, actually frustrated and counteracted the city's efforts on fair housing,” Peck said.

Price and Monterrubio also noted the demands are not coming in a vacuum.

For example, credit unions are gearing up for new standards on credit cards required under the Military Lending Act. On Feb. 16, CUNA asked the Defense Department to provide more clarification about credit card provisions of MLA rules scheduled to take effect Oct. 3.

CUNA said it expects to complete a survey of members by March 31 that it “expects will demonstrate the adverse impact the regulation is having on some service members. Specifically, the extent to which credit unions have had to discontinue certain products directly covered under the MLA regulation.”