Financial Privacy | Public Comments: WPF urges caution in creating new unique mortgage identifier number

WPF submits comments to CFPB about the Universal Mortgage Identifier number and Home Mortgage Disclosure Act

The World Privacy Forum has recommended privacy controls for a proposed Universal Home Mortgage Identifier number, along with other privacy protections to the Consumer Financial Protection Bureau in public comments on the Home Mortgage Disclosure Act. The CFPB recognizes that  the disclosure of detailed loan-level data about individual consumers to the public creates privacy risks. The comments the WPF submitted were in response to a notice of proposed rule making.

Essentially, the Mortgage Disclosure Act will release a great deal of very personal information about home mortgage owners into the public, at least potentially. The rule is not final yet.

Our comments note that the volume of data held by the consumer data industry has expanded greatly over the past several decades. The availability of additional identifiable information from social networks, behavioral tracking on websites, cell phone tracking, surveillance cameras, facial recognition, and other commercial and technological developments has contributed to privately held and unregulated consumer databases. These trends will  continue. Technology always outpaces the ability of regulators to adjust so it may be necessary for CFPB to anticipate developments to some extent. In factoring in legal developments, WPF suggested that CFPB consider that states have been much more active in enacting privacy legislation than the Congress, and we expect this trend to continue.

WPF specifically suggested that to control and balance privacy risks, that CFPB use data use agreements to restrict use of data. We also suggested  that data released to the public should not contain specific date of birth of mortgage holders to the public.

Of great interest is CFPB’s proposal to create two new unique identifiers akin to the SSN in many ways.  One is a universal mortgage identifier (UMID), and the other is a unique parcel identifier. WPF recommended that CFPB not link personal information to the UMID, control its collection, and assess the UMID for impact on victims of domestic violence and other vulnerable populations.

Read WPF comments on CFPB Mortgage Disclosure proposal (PDF, 18 pages) 


SEC comments Asset-level privacy, April 2014 (Revised rule making)

SEC comments, Asset-level privacy August 2010 (NPRM)