I am curious as to the structure you have in your bank on the gathering of the HMDA data and who is ultimately responsible for the verification of the data. I have a few questions below, any feedback would be greatly appreciated.
1. Asset Size?
2. How many individuals do you have that is ultimately responsible for the verification of the HMDA data?
3. What department do these individuals report to?
4. How many are in this department?

BGirl, as banks run from $10 mil to a few trillion, it might be better to give your bank size (range) and your complexity and ask for similar banks to respond. It could be a waste of time for a bank outside of your class to respond. (A multinational bank would be irrelevant to you if yours is a community bank.)

We are considered a 'small' bank as far as asset size, and we tend to report around 600 apps on our HMDA LAR. I am the HMDA/CRA specialist in our bank and that is my only job. I have my loan officers fill out the HMDA Reporting Form for their HMDA applications and I verify the information and load to the LAR manually. I also gather and verify all CRA information. This is just the way that our bank does it. Larger banks that use a software to gather loan information from their core may have one or more people in their compliance department that verify the data. I believe it should ultimately be the bank's compliance department that is responsible for this highly important area we are to be compliant with. I hope this helps!

What are you going to do when the # of LAR fields triple as of 1/1/2018? You are going to need a more efficient process for data entry for 600 applications.

Not to mention every time you transfer information you open another window for errors to come in.
Your core system undoubtedly has the ability to produce a LAR so why not use it and eliminate the HMDA Reporting Form?
Verify, export and scrub from there.
As Kathleen states, you need to be getting more efficient now.

We still use the FFIEC software and I manually enter all of the entries; however I do know that beginning in 2018 that we will need to go a different route. My concern with having the front line enter the items is garbage in - garbage out.

How do you HMDA?

1-2, 123 - 1-2, 123 - 1-2, 123

Oh, that's the .... nevermind ....


Sorry couldn't resist.

No Dan - that's the Rumba.

This is my thought too.....i currently hand enter into the DES as well, and i understand that that will become much more problematic in 2018....i simply don't trust everyone else to enter it correctly (and Lord knows, i won't trust them when the fields increase by 500%). I need a revelation on how to change the process.

". . .and i understand that that will become much more problematic in 2018....i simply don't trust everyone else to enter it correctly (and Lord knows, i won't trust them when the fields increase by 500%). I need a revelation on how to change the process. . . "


Just imagine the 2018 training and subsequent scrubs!

I agree with Skittles comment. Having loan officers enter the data....even with efficient training efforts is fruitless. I have been looking at HMDA for years from three different banks. I hate to be negative nelly, but lenders' focus isn't there for HMDA. Some don't even recognize which loans are HMDA reportable and which ones are not....a week after I have conducted extensive in-person training. For example, lenders' continued belief that a 1-4 family rental property is "commercial property" and therefore not reportable, even after training with an emphasis on the fact that the property is a residential property, not a commercial property. They simply think on a different level and seems for the most part, don't care. Then there are the lenders who seldom extend HMDA reportable loans and so when they have one, they don't think about reporting it. The compliance officer and I have to scour reports in an effort to identify loans that never made it to our LAR. Home equity loans....they will submit non-reportable ones to the LAR and miss reportable ones. Rant over.

FYI...we DO have a mostly automated process. But mistakes run rampant.

The more i think of it...i already have my hands on every real estate loan we do, both pre- and post- closing.....of course, lending staff will have to be trained in the gathering aspect of all of this, but i'm not sure that my 'scrub' of the data can't just occur in my pre-closing review, which would accomplish what i do now post-closing.

^^^this is what I do. And then I rescrub at post closing and then quarterly pivot table and transfer to FFIEC.
I certainly wouldn't want sole responsibility for entering all the info myself. That's a two-edged sword.
Of course, I'm working with mortgage staff entering the application info into our LOS, not LOs.

It depends on what you mean by sole responsibility..........i do (and probably will continue) to enter all the info myself into the DES; but of course, lending staff gathers it (and does "enter" it into our LOS, it's just that i don't pull it over from the LOS to the DES; that's the part i do manually).

That's the step I'm suggesting be eliminated.
There are a number of benefits of pulling the LAR from your LOS rather than manually entering every loan in DES.
1) you don't have to do it all yourself
2) you can identify the areas and/or individuals that need further training
3) because you make your corrections in the LOS, the information is correct in all areas of the bank, not just on the LAR
4) you train those entering the information to take it directly from the application eliminating worksheets, etc.

I'm just putting forth a suggestion for making it easier now before we have so many more fields to scrub.

Thanks....i do make sure those changes happen in the LOS now; i guess it's just residual mistrust that keeps me from pulling information directly from the LOS (that, and my LAR is small enough that it's not a major chore to hand enter them). I get the training aspect of this; i really do....but every bank culture is different, and i've positioned myself (probably foolishly on my part) as the conduit for everything here....it all flows through me. I don't know that i'm ever going to be comfortable trusting my loan staff to have learned this stuff the way i have; i try to use my corrections of their errors as my teachable training moments, with the hope that enough of that from me will mean improvement from them (mixed results i admit; some of them very much improve in this way; others, not so much). When the culture of our bank means that compliance examinations basically fall in my lap, i'm going to rise or fall based on what i told people to do and from the stroke of my pen as much as possible; i simply don't want to be judged on the lowest common denominator in my bank; so i check and re-check everyone's work. I know it's probably far from the most efficient system i could employ, but it seems to work for us so far. These changes (and more regulatory changes) may of course cause me to change my tune if the workload simply gets to be too much.

Without management support, there will be no progress in creating an efficient, accurate HMDA process.

I will agree on the efficient part i guess; but i'm able to have an accurate process (so far).

But i agree.....if people were held accountable for their deficiencies, it would be helpful. For now, i have to live with the reality of the situation.

What are you and the bank going to do when the BIG truck gets you on the way to or from work one day? I hope you have a back-up that knows this as well as you do, or you're going to leave the bank in an awful place. I'm speaking from experience. Only I knew how to complete a Call Report - not a problem until my appendix ruptured the day after Christmas. I went back to work after three and a half weeks, against doctors orders. We had a Call Report to submit. I've been paying the price ever since. Now I make sure someone else knows how to do the things that have deadlines just in case. Just something to think about.

Never a truer statement has been said....

You all are speaking to the choir really, but i haven't the power to pull someone aside and say "hey....i'm gonna teach you all of my stuff so you'll know it in case i'm not here".

I already have panicky processors who freak out when i'm out of the bank for a day or two......but it's not my job (nor is it within my power) to create my backup/successor plan.

no but you can put what you do in written directional form. Not the minutiae, but the gist of it. Examiners are asking to see this too.

I do this.