I have recently joined a 600M community bank with a Mortgage Company subsidiary as the Compliance Officer (with several years compliance experience).

Any previous bank I've know, the responsibility for completing the HMDA LAR resides in the loan department and the Compliance department is reaponsible for auditing the data to ensure accuracy.

At this bank it resides completly in the Compliance Department, from data entry through annual filing.

I would like to know where that responsibility resides in your bank. My hope is to encourage bank management to move this responsibility in the future.

Loan Dept and Mtg Dept do the review and data entry / compliance audits quarterly.

Loan department has responsibility for completing and auditing LAR. $1.1 billion bank.

In my previous life, our LAR responsibility fell to the Loan Operations Department. Then it was moved from there to the Compliance Dept. We had a seperate Audit Dept. that handled the auditing of the data. (Started at $5M and left at $1B)

Where I currently work, it's all in Compliance.

Lending department completes the data sheets, and Compliance audits quarterly as well. We are under $1 billion.

Bank $248 million. When I came on over 8 years ago, this bank had some HMDA issues so I have total HMDA responsibility. Neither loan officers nor loan administration has level of understanding (even though I train) to undertake.

I validate each line item for LAR, I input into FFIEC software. Another person checks my entries.

HMDA errors are rare. A lot of work up front, but it helps when regulators come in, especially for fair lending.

We averaged 545 LAR entries annually from 2008 - 2011. 198 so far this year.