If for whatever reason, a loan should have been on the HMDA LAR for 2010, should I re-submit my HMDA LAR for 2010? As an aside: We had a CRA exam this year and they looked at 2009 - 2011. Can provide more details if necessary.
Thanks

If you have already been examined, I would not bother for one loan regardless of overall LAR size. Make sure you understand why it was missed so that hole can be plugged.

I thought that initially but thought what if this loan is pulled for other reasons that CRA and they check to see if it was filed on the LAR? Or is that even a remote possibility?

Unlikely, but how many applications are on the lar it was omitted from?

The FDIC does now have (at least in our region) teams that specifically look at HMDA accuracy prior to the full compliance examination. Even at that it is highly unlikely they would note that single loan unless your LAR is extremely small. I would be resistant to re-submitting over a single loan from 2010. Most examiners that I know wouldn't make a big deal out of it as long as you took steps to correct the problem going forward. However, if you only have 20 items on your LAR that would certainly increase your risk.

In this case, the bank was already examined on the data...hence my hesitance to worry about resubmission.

The LAR had about 52 loans.

You stated that the bank had already been through a CRA exam, which includes HMDA, on this time period. These loans will not be re-examined for those purposes.

Do you have any upcoming consumer reg exams that could include this time period for HMDA reportable loans? If yes, I would consider refiling, but would probably ask my examiners if they wanted the bank to bother for the 1 loan.