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#1887403 - 01/16/14 03:14 PM HMDA monitoring
Anonymous
Unregistered

Fairly new to the world of HMDA, especially monitoring. I am wanting to get some opinions/insight as to how others out there monitor their HMDA LAR. Is this done daily, weekly, monthly? I would like to come up with an more effective approach, other then semi-annually. Thank you.

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#1887406 - 01/16/14 03:17 PM Re: HMDA monitoring Anonymous
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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We monitor quarterly since Reg C requires the LAR to be updated within 30 days after the end of the quarter in which the loans were made/denied/withdrawn. Hope this helps!
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#1887432 - 01/16/14 03:53 PM Re: HMDA monitoring Anonymous
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,782
The Mitten State
I monitor monthly. Seems to be less time consuming and less of a headache.
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#1887440 - 01/16/14 04:05 PM Re: HMDA monitoring JWills, CRCM
Ski Offline
Platinum Poster
Joined: May 2003
Posts: 639
South Louisiana
Because of past problems with having to re-submit (before I came here), I check all HMDA daily. I have tried training and retraining, but some consumer loan officers just don't get it. None of the commercial loan officers care. Management is only concerned with making sure it gets done and we have no problems from regulators.

It will be interesting when I retire in about two (2) years if someone doesn't step up, learn it well and keep it up.

Assess your loan officer's (or assistant's) capabilities and adjust as needed. Management and the board will only get involved if you have problems, but keep them informed of your efforts, so when IT hits the fan, it doesn't come down on YOU.

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#1887463 - 01/16/14 04:24 PM Re: HMDA monitoring Anonymous
Anonymous
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OP 2: Monthly. At our shop, it feels like doing it quarterly would be overwhelming, in consideration of the loan volume. As long as you are doing it quarterly or more often, you are in compliance.

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#1887468 - 01/16/14 04:27 PM Re: HMDA monitoring Anonymous
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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Good point. Depending on your volume (or the amount of staff you can devote to HMDA monitoring), quarterly may be too infrequent.
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We're all here 'cause we've lost control.

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#1887570 - 01/16/14 05:37 PM Re: HMDA monitoring Anonymous
Anonymous
Unregistered

Orignal Anon here; what are you tracking to ensure HMDA is correct? I eneter the info on the LAR but have concerns that not all files are coming to me.

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#1887583 - 01/16/14 05:52 PM Re: HMDA monitoring Anonymous
JWills, CRCM Offline
Diamond Poster
JWills, CRCM
Joined: May 2013
Posts: 1,782
The Mitten State
I get a new loan report each month covering all loans done the prior month. I go through them all and remove the ones I know are not HMDA reportable, and then focus on those. In a sense I could have all files sent to me, but I feel the list is sufficient, and then I ask for files. It has been working so far.
_________________________
Nonsense wakes up the brain cells.

--Dr. Seuss

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#1887587 - 01/16/14 05:54 PM Re: HMDA monitoring Anonymous
Ski Offline
Platinum Poster
Joined: May 2003
Posts: 639
South Louisiana
We are a small shop; About 350 LARS annually. Assets under $300 million.

Again, because of issues that do not seem to be able to be resolved by management, I check EVERY loan that is originated before it is uploaded to the core system plus all denied, counter-offerred, approved by not accepted, etc. That almost ensures that I see all applications to evaluate for HMDA purpose.

I also send an email around this time of year letting all loan officers know that I need for them to check and see if they have any "Pending" applications hanging around.

I validate EVERY field that needs to go on the LAR with something on the appl., income info, geo-coding, etc. Then I enter it into the FFIEC software. Then I have someone else check my input.

I'm sure there are better/more efficient ways of doing this, but my shop requires a heavy labor intensive HMDA effort.

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#1887594 - 01/16/14 06:00 PM Re: HMDA monitoring Anonymous
luvs2trvl Offline
100 Club
Joined: Apr 2013
Posts: 110
Texas
We monitor monthly then again at the end of each quarter just to make sure.

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#1887609 - 01/16/14 06:21 PM Re: HMDA monitoring Anonymous
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,397
We have around 3k lines on our LAR annually. Info is entered into our loan software and I export it to the HMDA submission software. I use pivot tables to scrub quarterly and again at the end of the year. I also investigate missing loan numbers on the LAR to verify that they're not really HMDA reportable.

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