I'm new to internal auditing and a HMDA audit has been listed on our Audit calender. We are a non-HMDA bank. Where would I start, and what exactly would I audit?

Can't think of a single thing except possibly ensuring that your bank still isn't covered by HMDA (checking the asset threshold, making sure you don't have a branch in an MSA, etc.).

To help you look at the issues raitchay mentioned review the following document:

http://www.ffiec.gov/hmda/guide.htm

Start with "Who Must Report" on page 3.

During our most recent CRA exam, our examiner actually told the bank president and me that we should be reporting HMDA data, even though we are NOT a HMDA bank. He actually asked why we didn't report.

If you are not a HMDA REPORTER, examiners will tell you that you need to COLLECT the data anyway for your CRA exams.

We are HMDA reporter so I am not sure, but I seem to remember that as an OCC bank we were required to keep the records even when we did not report.

Are these examiners going so far as to say you should collect GMI on home improvement loans, even if not a HMDA reporter? That would seem to lead banks down the road of non-compliance.

Thanks everyone!

I know as a non-HMDA, OCC regulated bank we still need to comply with the Federal Housing Home Loan Data System. I guess that would be another area to Audit as well.