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#1712545 - 06/20/12 07:33 PM HMDA audit for Non-HMDA bank?
rachelchri Offline
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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?

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#1712553 - 06/20/12 07:37 PM Re: HMDA audit for Non-HMDA bank? rachelchri
raitchjay Offline
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OK
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.).
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#1712591 - 06/20/12 08:34 PM Re: HMDA audit for Non-HMDA bank? rachelchri
Dan Persfull Offline
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Bloomington, IN
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.
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#1712610 - 06/20/12 09:23 PM Re: HMDA audit for Non-HMDA bank? rachelchri
SLU Voice Offline
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Hammond, LA
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.

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#1712722 - 06/21/12 02:28 PM Re: HMDA audit for Non-HMDA bank? rachelchri
SMQ, CRCM Offline
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Between the lines
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.
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#1712725 - 06/21/12 02:35 PM Re: HMDA audit for Non-HMDA bank? rachelchri
raitchjay Offline
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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.
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#1712782 - 06/21/12 03:32 PM Re: HMDA audit for Non-HMDA bank? rachelchri
rachelchri Offline
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Joined: Aug 2010
Posts: 165
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.

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