I really need to get a formal written policy and procedures together for HMDA. I've never written any from scratch, are there any examples out there somewhere or would anyone be willing to share theirs? Thanks!

I don't have any to share, but I would recommend you NOT have a HMDA policy. It's not required by regulation. You should have procedures, however.

I absolutely agree with David. Your procedures will be determined to some extent by the loan origination software that you use, and the HMDA compilation and transmission software that you use.

I would suggest that your procedures identify by whom and how:

1) the HMDA is collected
2) the data is input into your LOS
3) the data is imported into your HMDA software
4) the data is verified and scrubbed
5) the HMDA report is transmitted

Okay... great Thank you!!! How do we know if we need a written policy? It would say in the actual reg? Thank you both!

That I am aware of, you do not need a policy. To add to Sinatra Fan - keep it simple. I have a flow chart with the designated responsibilities and it is filed with general loan procedures.

Regulators want to see instructional procedures for HMDA to ensure that staff knows how to apply the regulation and how to properly process loan applications, filling out appropriate internal forms/systems screens to get the correct data to the right place.

I have seen regulators actually require screen shots and sample forms in procedures when a bank has persistent errors. Those items do make for a good instructional procedure.

A policy adds no value in this situation - what would it say? We will comply?

That's what I say, Kathleen, but I've been asked by the FDIC to develop a Policy. I think it will be a 2 paragraph model.

I agree. Have a brief policy and reference the procedures, that have the detail.

I have used an overall compliance program for the policy statement successfully, with detailed procedures for the individual regs.

Does everyone agree that if you have a commercial entity as an applicant and no coapplicant, you would report ethnicity, race sex codes of 4,7,4 and 5,8,5 respectively?

I've seen it banks report the co applicant as 4,7,4 also and it makes sense to me either way...just wondered if there was a standard that agencies want to see.

I know that page 20 of the GIR Guide states, "If there is no
co-applicant, use the numerical code for “no co-applicant” in the “coapplicant” column." but I have been cited for using the Guide before when the agency reviewing the LAR doesn't agree.

If there is no co-applicant and applicant is an "entity", you use 5 8 5 for co-applicant. Otherwise, you are stating you have a co-ap.

Thank you for confirming.