I would like to find out how other banks handle the whole HMDA process.

1. Do you use a sheet to combine all the info that goes on the LAR and if so, who completes that sheet and is responsible for it being accurate?

2. Who enters the data on the LAR and is responsible for it being entered accurately?

3. What check-points are set up to review for accuracy? Are they done at each step, or one time after everything is entered on the LAR (monthly or quarterly), and who is responsible for them?

Anything else that you do that I didn't cover is appreciated too. Thanks!!

Earlier Thread has some info that may help you.

$2 billion bank - Initial DAT files or spreadsheets come from each lending department. Mortgage department uses Encompass. Commercial loans uses Laser Pro for originations. The lenders complete HMDA worksheets for non-originated that I input manually. Consumer loans uses Velocity. Each area is responsible to get me a clean file. The mortgage department tests a 10% sample of their loans before sending the file to me. They will test more files if they find problems. Mortgage sends me their loans monthly. Consumer and commercial send theirs quarterly. When I get the files I import them into CRA Wiz which creates edit/error reports that are sent back to the departments to resolve.

In the mortgage department, there are people who review the pipeline and "fall out" loans ongoing to make sure applications are resolved in a timely manner.

The lending departments are responsible for getting me accurate data. However, it helps to ask a lot of questions, do some file reviews. Additionally I review the commercial loan non-originated loan log periodically and research any loan that looks like it might be HMDA reportable. I also get a monthly database of all originated loans and double check anything that is residential secured, particularly in a commercial lending product, to see if it should be HMDA reportable.

We use an independent compliance consultant to do a validity test at year end. Also, I come to many staff meetings to bring up any problems I have noticed.

I don't like the idea of copying info from the application to then be entered into the LAR. It's one more place for an error to occur. We enter everything from the application directly into the LOS.
LOS produces the LAR which I pivot and scrub.
Corrections are made to LOS where necessary and then exported to the HMDA DES for submission.
Everyone in the department is trained in HMDA annually and is responsible for accuracy.
Several checkpoints are built in to our process so the data is reviewed often including three times that must be acknowledged on worksheets in the file.
I've incorporated a HMDA review step into my FNMA LQI review too.