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#1712239 - 06/20/12 02:54 PM Optional Reporting for Purchased Loans
JSD Offline
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Do you know if an institution can report some of the optional data, but not some of the other optional data fields? For example on purchased loans you don't have to report the income or Race/Sex/Ethnicity (along with some other fields that are optional). Can a bank elect to report let's say income, but not the R/S/E? My first thought is that it's all or none, but then I think about the collection of Government Monitoring Information and that you can report some of selections as well as report not provided for some. Thanks!

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#1712248 - 06/20/12 03:09 PM Re: Optional Reporting for Purchased Loans JSD
Truffle Royale Offline

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Let's think about this for a second.
Every piece of information you put on a LAR, whether it's required or 'optional' is subject to verification by examiners.
So if you don't HAVE to put info in there that could become an error, why would you?
Take it from someone who knows firsthand, you do not want to be on the receiving end of errors in optional reporting fields.
They burn just as badly as the ones you're required to report.

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#1712278 - 06/20/12 03:36 PM Re: Optional Reporting for Purchased Loans Truffle Royale
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TR, I agree and that is why we elected to not report when the Reg gives you an otpion, but we have a group that is wanting it to be provided and just checking out our risks and if you can do partial reporting on optional data.

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#1712300 - 06/20/12 04:01 PM Re: Optional Reporting for Purchased Loans JSD
Kathleen O. Blanchard Offline

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Take into consideration why you are purchasing the loans. If you are purchasing them to improve your HMDA/fair lending standing, then you will want to report that data as without it you won't have proof of more loans to low/moderate borrowers or better lending based on race/sex/ethnicity.
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#1712308 - 06/20/12 04:06 PM Re: Optional Reporting for Purchased Loans JSD
Quatro Offline
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What benefit is there to reporting optional inoformation, or some information and not others, as that group wants to do? I don't know of anything that states reporting optional data is an all or nothing deal, but my bank takes the stance of not reporting optional data for the reasons TR says.

I'm willing to bet the people that want to report the optional data will not have fingers pointed at them should errors occur and CMP's happen.
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#1712314 - 06/20/12 04:13 PM Re: Optional Reporting for Purchased Loans Quatro
Kathleen O. Blanchard Offline

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Originally Posted By: Quatro
What benefit is there to reporting optional inoformation, or some information and not others, as that group wants to do? I don't know of anything that states reporting optional data is an all or nothing deal, but my bank takes the stance of not reporting optional data for the reasons TR says.

I'm willing to bet the people that want to report the optional data will not have fingers pointed at them should errors occur and CMP's happen.

But refer to my post: if you are purchasing for fair lending reasons, which many banks do, you need that data.
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#1712319 - 06/20/12 04:19 PM Re: Optional Reporting for Purchased Loans Kathleen O. Blanchard
JSD Offline
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Yes, those are all valid concerns related to CRA KB. These loans don't fall into that category - these are happening in our correspondent lending area & are not being purchased to improve our stance for CRA. Just need to find out on optional data if you can report some and not report some of the other field that are all optional.

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#1712328 - 06/20/12 04:23 PM Re: Optional Reporting for Purchased Loans Quatro
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Q, yes it was very explicit to the group for the need of a good scrubbing of the data since it is collected by a third party. Since the income data field has the highest error rate per the regulators, it is of a great concern to be reporting more of the income data than one has to reported.

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#1712390 - 06/20/12 05:20 PM Re: Optional Reporting for Purchased Loans Kathleen O. Blanchard
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Originally Posted By: Kathleen B
But refer to my post: if you are purchasing for fair lending reasons, which many banks do, you need that data.

Sorry, KB. You posted while I was trying to type out my reposnse. smile You're too quick!

For fair lending it could definitely help the LAR. I guess it comes down to how confident you are with the accuracy of the data reported, and JSD has informed the powers that be of the need for a thorough scrub.

JSD, I don't think there is anything in the GIR that says if you report one optional field, you must report them all. I could be wrong on that, but I don't recall seeing it or reading it.
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