Skip to content
BOL Conferences
Thread Options
#2048105 - 11/04/15 08:50 PM HMDA Corrections...
workerbee Offline
Member
Joined: Oct 2015
Posts: 61
What is your take on a HMDA Specialist making corrections to data errors?

Return to Top
HMDA

   
HMDA Academy
#2048106 - 11/04/15 08:50 PM Re: HMDA Corrections... workerbee
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Can you explain a little further. Is this current year data caught during a review? Is it prior year?
_________________________
My Opinions Only

Return to Top
#2048107 - 11/04/15 08:52 PM Re: HMDA Corrections... workerbee
workerbee Offline
Member
Joined: Oct 2015
Posts: 61
Current year data caught in a review.

Return to Top
#2048116 - 11/04/15 09:09 PM Re: HMDA Corrections... workerbee
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
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?
_________________________
I'm fixin' to fix that.

Return to Top
#2048117 - 11/04/15 09:10 PM Re: HMDA Corrections... workerbee
workerbee Offline
Member
Joined: Oct 2015
Posts: 61
Yes. There are mixed feelings about whether it is a conflict of interest for someone reviewing the LAR and then correcting errors found.

Return to Top
#2048118 - 11/04/15 09:10 PM Re: HMDA Corrections... workerbee
workerbee Offline
Member
Joined: Oct 2015
Posts: 61
Yes. There are mixed feelings about whether it is a conflict of interest for someone reviewing the LAR and then correcting errors found.

Return to Top
#2048119 - 11/04/15 09:11 PM Re: HMDA Corrections... workerbee
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
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.
_________________________
My Opinions Only

Return to Top
#2048120 - 11/04/15 09:14 PM Re: HMDA Corrections... workerbee
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
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.
_________________________
I'm fixin' to fix that.

Return to Top
#2048121 - 11/04/15 09:16 PM Re: HMDA Corrections... workerbee
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,088
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.
_________________________
I'm fixin' to fix that.

Return to Top
#2048128 - 11/04/15 09:30 PM Re: HMDA Corrections... workerbee
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
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.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#2048135 - 11/04/15 09:48 PM Re: HMDA Corrections... workerbee
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
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.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2048362 - 11/05/15 09:32 PM Re: HMDA Corrections... workerbee
JC (Darth HMDA) Offline
Diamond Poster
JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
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!
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

Return to Top

Moderator:  SMQ, CRCM