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#361342 - 05/19/05 05:15 PM Refile Data
Anonymous
Unregistered

We have found several errors in our HMDA LAR and we don't know if we should resubmit. What is the rule of thumb and how do you resubmit?

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CRA
#361343 - 06/02/05 04:49 PM Re: Refile Data
Anonymous
Unregistered

Our institution contacted the Federal Reserve and let them know that we needed to resubmit. They wanted us to as quickly as possible because they were tabulating the peer numbers. I'm not sure what a rule of thumb might be, but I would fix the errors and resubmit regardless. Examiners would make you do it anyways and cite you for the errors, I don't believe you would be cited if you found and corrected the issues prior to an exam.

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#361344 - 06/03/05 11:14 PM Re: Refile Data
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
10% overall errors, or 5% in any one key field is cause for a complete scrub and resubmission. It's also cause for possible fines and punishments offered up by the feds if they're in the mood.

But, they might not like 4% in a key field if they think the data is significant for exam, so they could make you scrub for that as well and resubmit.

I set a goal of below 2% overall at the very highest. I have procedures in place to keep me below that figure. If I found I was close to 3% I'd resubmit immediately. Fix as much as you find suspicious (something led you to this decision obviously) and try to limit a year's loans to only one resubmission. Document why you chose to do this, so when exam time comes around you can show what an on the ball person you are You'll look better in the eyes of your examiners.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#361345 - 06/04/05 12:03 AM Re: Refile Data
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
The below information was posted in the general threads. David Dickinson has covered the HMDA issue so well in his newsletter I thought I'd copy and paste the post here as well.


"We just included a summary of the HMDA tolerances in our latest E-newsletter. You can get it at our website (scroll down to the bottom to see the Newsletters). Click on the "June 2005" link."

http://www.bankerscompliance.com/downloads.htm
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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