Has anyone gone through one of the new FDIC on-site HMDA validations that are now being done prior to compliance exams....are we in for a fun time or what? We are told that the previously filed LARs from the last exam to the prevent will be tested to make sure there are no fair lending issues and to make sure the data is good before an exam commences on site-makes sense, but also makes me nervous. Any feedback?

OCC has been doing this for years. If you feel your data is clean, you should be okay. In a sense they are splitting what (should have) has been done in one exam into a pre-exam and exam.

Do you scrub your HMDA data? Do you look for evidence of discrimination in your lending products? If so, you shouldn't have surprises.

What MS Kaybee said.

If you have procedures in place to validate and cross-validate your data before you send your annual data by March 31st, you should be OK. If you only "spot check" your data, you might be in for a nervous experience.

Even though I have check and cross check procedures, I still get nervous and I have been doing this 30 + years. If I don't get a little nervous, I will probably miss something.

Hope this helps.

Okay, then we have nothing to worry about-we have a quarterly review process in place. Just not liking to have them hanging around any more than usual. Maybe our regualtors are just catching on to what other regulators have been doing for a while. Is the OCC the only other regulator doing this? I have heard from OTS regulated friends that they don't have this in place now but have not asked Fed pals.....

Thanks.

The FRB does this too.