CFPB issues interpretive rule to guide which counties are “underserved”

The Consumer Financial Protection Bureau (CFPB) issued an interpretive rule last week, providing guidance about the way the agency determines which counties qualify as “underserved.”

The Home Mortgage Disclosure Act (HMDA) data was previously used to determine which areas met the underserved standard using a method contained in Regulation Z. However, portions of that method became obsolete due to reliance on data elements that were modified or eliminated by 2015 amendments to the HMDA regulations, which became effective in 2018, according to the CFPB.

The interpretive rule describes the HMDA data that will instead be used in determining whether an area is underserved for purposes of the standard described in Regulation Z. This interpretation supersedes the outdated methodology set forth in the commentary to Regulation Z.

The interpretive rule can be accessed by clicking here and a list of rural and underserved counties, using the HMDA data described in the rule, can be accessed on the CFPB website.


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The League of Southeastern Credit Unions & Affiliates represents nearly 300 credit unions throughout Alabama, Florida, and Georgia. It has a combined total of almost $200 billion in assets and 12.4 million members. LSCU provides advocacy, compliance services, education and training, cooperative initiatives, and communications.

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