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#2048105 - 11/04/15 08:50 PM HMDA Corrections...
workerbee Offline
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Joined: Oct 2015
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What is your take on a HMDA Specialist making corrections to data errors?

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#2048106 - 11/04/15 08:50 PM Re: HMDA Corrections... workerbee
Skittles Offline
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Can you explain a little further. Is this current year data caught during a review? Is it prior year?
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#2048107 - 11/04/15 08:52 PM Re: HMDA Corrections... workerbee
workerbee Offline
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Current year data caught in a review.

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#2048116 - 11/04/15 09:09 PM Re: HMDA Corrections... workerbee
raitchjay Offline
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OK
Do you mean: you have someone whose job it is to review the current year LAR for input errors, and they found one, and they corrected it?
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#2048117 - 11/04/15 09:10 PM Re: HMDA Corrections... workerbee
workerbee Offline
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Yes. There are mixed feelings about whether it is a conflict of interest for someone reviewing the LAR and then correcting errors found.

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#2048118 - 11/04/15 09:10 PM Re: HMDA Corrections... workerbee
workerbee Offline
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Yes. There are mixed feelings about whether it is a conflict of interest for someone reviewing the LAR and then correcting errors found.

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#2048119 - 11/04/15 09:11 PM Re: HMDA Corrections... workerbee
Skittles Offline
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I do that. I am responsible for our HMDA LAR. I enter the information onto the software and scrub quarterly. At our last exam we did very well with the HMDA data. I am the Compliance Officer here.
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#2048120 - 11/04/15 09:14 PM Re: HMDA Corrections... workerbee
raitchjay Offline
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OK
I'm the only person at my bank who has anything whatsoever to do with our LAR...so i input the information...and if i find later i made an error inputting it...i correct it. I see no conflict of interest there.
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#2048121 - 11/04/15 09:16 PM Re: HMDA Corrections... workerbee
raitchjay Offline
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OK
I guess my feelings would be...if you trust the person to review the LAR, why wouldn't you trust them to fix the errors? But it would come down to job description i guess....if you have multiple people involved, and the person reviewing is merely supposed to find errors and report them as such and let someone else correct them, that's for your bank to decide.
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#2048128 - 11/04/15 09:30 PM Re: HMDA Corrections... workerbee
David Dickinson Offline
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Central City, NE
It depends. If the reviewer found a rounding error or a transposing error, why wouldn't you want them to fix it? If they found an application date that they couldn't reconcile, they should kick it back to the person that completed the data and ask "Are you sure? I can't support it." (or something similar).

Some errors just need fixing (rounding, obviously "fat finger" errors), some need an explanation. Some trigger training for the input person or decision maker. So it all depends on what you're talking about. Maybe you can give more details and why you question the reviewer.
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#2048135 - 11/04/15 09:48 PM Re: HMDA Corrections... workerbee
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Especially for a small shop, I would be okay with it, but I do think there should be records maintained to demonstrate the process and that it is working. If it is just the person reviewing what they just typed, okay, just fix it.

If it is a more formal review, a record of errors identified and errors corrected, with detail on the bigger errors like the application date example.
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#2048362 - 11/05/15 09:32 PM Re: HMDA Corrections... workerbee
Darth HMDA, CRCM, CAMS Offline
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Joined: Dec 2013
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Sometimes out of necessity the person filling out the LAR is also responsible for reviewing it. (Im now stuck in that boat). Although I don't think there is anything inherently wrong with it, I think it is incredibly risky to only have one level of control/review for something as high-risk as HMDA.

That being said, if I fat fingered something that caused an edit to come up I'm going to have to clear it either way. I don't think it is a conflict of interest. If you don't correct it, and no one else corrects the LAR you kind of have to correct the error.

Good luck!
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