CML has responded to FCA's consultation on the regulatory reporting requirements arising from the Mortgage Market Review (MMR). It notes how the number of data items contained in a product sales data report could increase, under current proposals, from 31 to 130, and says FCA has underestimated the costs of this increased reporting burden. For that reason, CML says it is important that firms understand better the justification for increased data collection so that they can deliver it efficiently. For example, CML asks for clarification that affordability data will not be used to reproduce individual underwriting decisions, as this could affect firms' flexibility to determine their own approach within the overall responsible lending framework. Consumers also need reassurance that their data will be collected and used for their benefit. (Source: CML Response to CP13/02)