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#179337 - 04/13/04 07:24 PM HMDA resubmission
Peepers Offline
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What kind of problems (if any) should I anticipate if I have to resubmit?

FDIC called and had a question about 19 loans on our LAR (missing geo code info.). They are e-mailing the information.

I was wondering if anyone knew of any penalties we may be facing for this. This is the first time I may have to resubmit.

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Lending Compliance
#179338 - 04/13/04 08:37 PM Re: HMDA resubmission
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,249
Bloomington, IN
There will be no real problems other than you may have to do a complete file review for 2003. That and any penalties will depend on the FDIC.
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#179339 - 06/29/04 07:11 PM Re: HMDA resubmission
RR Joker Offline
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RR Joker
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The Swamp
During an interim review, the FED found enough errors in our LAR to require full file review and resubmission. To make a very long story short...I have done a full sample and found there remains a 10% error rate. Exactly 8 errors within critical fields out of around 70 loans reviewed. My opinion is that all files will need to be looked at again...any one have an opinion? I think it would be highly frowned upon when they pull a sample next go-round and still find errors...this is VERY frustrating to say the least...anyone else had this much trouble with accuracy??? and what did you do to eliviate the problem going foward...obviously we have revised procedures and documentation. Any thoughts? Also, we only have a couple weeks remaining on our time limit to resubmit. Anyone ever have a "failed" review on the same data year 2 times?
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#179340 - 06/29/04 07:17 PM Re: HMDA resubmission
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,877
TN
I have been through something similar and it's not fun. Do you know where your errors occur? In my opinion, you need to narrow down where this is actually taking place and address it there.

The instition where I work now had horrible error rates. I would audit and they would fix them and continue putting information on with up to 80% error rates. Finally, we have one person putting all information onto the LAR and she does a great job. Error rate down to 5% or less.
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#179341 - 06/29/04 07:36 PM Re: HMDA resubmission
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,637
The Swamp
One person is responsible for input...She is the HMDA/CRA officer for the bank. She was recently moved under me and we have worked out solutions for much of the problems. However, with so many errors to start with and then looking back thru so many loans again...there are still errors. Nothing like it was...however not within tolerance. I plan on having someone else do the next review before we resubmit. The errors this go around are someewhat random. 1 Loan Amount, 3 occupancy, 3 income and 1 sex (only listing critical fields here) So, it's not one set problem area...it's just too many hours looking at tiny numbers and factor in human error so that it's still not up to par.
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#179342 - 06/30/04 11:35 PM Re: HMDA resubmission
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
Quote:

During an interim review, the FED found enough errors in our LAR to require full file review and resubmission. To make a very long story short...I have done a full sample and found there remains a 10% error rate. Exactly 8 errors within critical fields out of around 70 loans reviewed. My opinion is that all files will need to be looked at again...any one have an opinion? I think it would be highly frowned upon when they pull a sample next go-round and still find errors...this is VERY frustrating to say the least...anyone else had this much trouble with accuracy??? and what did you do to eliviate the problem going foward...obviously we have revised procedures and documentation. Any thoughts? Also, we only have a couple weeks remaining on our time limit to resubmit. Anyone ever have a "failed" review on the same data year 2 times?




I am a little confused. You said the Fed review required a "full file review" but you did a "full sample review" What is a full sample? From my understanding, when you are required to to a full review, that means pulling every file and reviewing for accuracy. You then make the necessary corrections and resubmit.

Going forward, I would suggest caning and electric shock with every error found. Ok, short of that, retraining and accountability. If you are doing the reviews, finding the errors and correcting them, then why should the person responsible do better, after all, you will clean it up. Where does this person get the info she enters? Does she have to pull it from the files or is it given to her from the loan operations staff. If they are providing her with bad data, then, unless it is her job to confirm everything given to her, they should be held responsible.

You might also remind the staff and management that there can be significant money penalties for HMDA errors.
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#179343 - 06/30/04 11:56 PM Re: HMDA resubmission
Truffle Royale Offline

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Doing a pivot table in Excel will all but eliminate your errors!!! The Feds were here for an interim review last fall and one examiner took the time to teach me how to do this. The only error we had on 2004 exam just concluded was due to an interpretation of the new rule and one quick global edit fixed it.

Our loan system produces a HMDA report which I save as an excel file with labels. Then you open that file in Excel, go under Data and set up a pivot table. This allows you to compare one column of the lar against another...say borrower race vs sex. If you get a "not applicable/male" you know you've got an error. Just click on the square where the blocks cross and it gives you the file number for the file with the error.

Needless to say, I am forever indebted to the Fed who took the time to teach and not just write us up!

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