I think what our examiners do is they take HMDA errors in a particular Loan File and count that as a loan with HMDA errors to try and decide if there are significant violations of HMDA or not. For instance, if 3 loan files out of 10 had HMDA errors whether one or more in a file,
that would be a 30% error exception for HMDA to determine patterns of non-compliance. Then when they decide if they need to assess civil money penalties or not, they take all
the possible fields on all the files (10 x 17 fields = 170 possible entries) and decide if the error % is over 10%.% is lower in this case. So they look at it in two different ways; one to detect a pattern and the second to assess cmp. Hope this helps.