WASHINGTON-CUNA wrote in a recent comment letter that it supported the revised format for public disclosure of Home Mortgage Disclosure Act data. CUNA's letter said the proposed revisions to the HMDA data disclosure are adequate for disclosing the new HMDA data. The trade association also supported the elimination of redundant information categories contained in the forms, which should make the disclosure tables more concise. The Fed's changes will modify several disclosure tables, delete some tables and add new ones. Recent amendments to Regulation C will bring them in line with those used by the Office of Management and Budget. According to CUNA's letter, they require: *The rate spread between the annual percentage rate on the loan and the yield on Treasury securities of comparable maturity when the spread exceeds three percentage points on first lien mortgages and five percentage points for subordinate lien mortgages. *Whether the loan is subject to the Home Ownership and Equity Protection Act (HOEPA). * Whether the loan involves manufactured housing. * The type of lien on the property. * Certain information about requests for pre-approval. "In general," CUNA wrote, "the HMDA data is submitted to the Federal Financial Institutions Examination Council, which creates the public disclosure statements that are then sent back to the lenders and made available to the public. We do not believe additional revisions are necessary at this time, especially since the public may request additional information at any time directly from the financial institution."