Tips On Preparing For New HMDA
At PCi's annual User Conference, several speakers shared their ideas for the transition to new HMDA. First, be prepared for last minute change. The Federal Reserve Board will be giving last minute instructions in response to questions that come in from the early birds. In addition to last minute advice from the Fed, you should look for changes to MSA delineations from OMB. When MSAs become MAs (Metropolitan Areas) the re-delineation may result in changes to numbers that had been familiar. It may also result in adjustments to median family income for the area.
HMDA veterans also recommend that each lending department or function have a designated HMDA officer who is responsible for capturing the data. Using a form or checklist for capturing data is a form of control used in many institutions.
Finally, plan ahead - way ahead. Many things can go wrong or change at the last minute. For example, find out now what the availability is for your MIS staff. Will they be available when you need them, or should you get them lined up now? Also, assume things will go wrong. As with disaster recovery systems, prepare for ways to cover the gaps that you know are likely to occur. For example, if you use systems to compile HMDA data, be prepared to use a paper-based system for several weeks (or months) as a back-up.
Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 5, 6/03
First published on 06/01/2003