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#2068059 - 03/08/16 06:33 PM Re: How do you HMDA? B-Girl
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
You can also make the recommendation of a back-up person to management.....in writing. So, if when you're out, they won't try pin the train wreck on you.
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#2068081 - 03/08/16 07:10 PM Re: How do you HMDA? B-Girl
RR Becca Offline
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RR Becca
Joined: Sep 2004
Posts: 5,245
out of the frying pan...
Wow - most of you either have WAY more authority than I do (and it sounds like raitch might), or you are fortunate enough to work for institutions structured in such a way that personnel gaps are a non-issue.
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#2068156 - 03/08/16 10:56 PM Re: How do you HMDA? B-Girl
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
I have no authority. Otherwise, I would put a thumb down on certain people when they report their HMDA data incorrectly. However, there are four on our compliance team so there is a natural backup for just about everything. At my prior bank, everyone was required to write intricate procedures about their tasks and submit to the manager for approval. That way someone could at least TRY to pick up the slack. Management that doesn't realize that there must be a backup plan/person for EVERYTHING, needs to go back to management school.
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#2068374 - 03/10/16 02:36 PM Re: How do you HMDA? B-Girl
rrush Offline
Member
Joined: Dec 2011
Posts: 74
We are a small bank also and submit 400 - 500 LAR entries annually. I pull data from our LOS systems that flow into HMDA Relief. We have a check and balance review that looks at a "proof" form against the file and then we check the LOS data against the proof. The lending staff is held responsible for what errors we find, so they have become "invested" in their success. I think they have their own double check now. We do this monthly then import the data quarterly. It is time consuming depending on our volume but I would not want to hand enter the information into the reporting software, too easy to make errors. I do training every quarter with the lenders and support staff on HMDA, basically on the errors we have found. Unfortunately, they don't remember real well smile But our error rate has gone from 35% to 1% - that of course is the error rate in our internal review, not the examiners.

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#2068411 - 03/10/16 03:55 PM Re: How do you HMDA? B-Girl
raitchjay Offline
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Joined: Oct 2009
Posts: 8,727
OK
Just curious....how is hand entering information into the LES any more error-prone than (lending staff) hand entering information into the LOS? (Or am i missing something?)
Last edited by raitchjay; 03/10/16 03:56 PM.
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#2068413 - 03/10/16 04:00 PM Re: How do you HMDA? B-Girl
raitchjay Offline
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Joined: Oct 2009
Posts: 8,727
OK
(Note here that i'm asking about error rate...i totally understand if one person hand-entering into a DES is too large a job..i get that.)
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#2068415 - 03/10/16 04:13 PM Re: How do you HMDA? B-Girl
rrush Offline
Member
Joined: Dec 2011
Posts: 74
The information loaded into the LOS is checked for errors by compliance. If we then had to re-enter into reporting software, more errors could occur. It is a matter of one person with a bunch of data compared to several people doing it at a transaction level, I think. We tried the other way, took too long and then we had to check the data entry. This way we only have one review of the data instead of 2.

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#2068421 - 03/10/16 04:20 PM Re: How do you HMDA? B-Girl
RR Becca Offline
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RR Becca
Joined: Sep 2004
Posts: 5,245
out of the frying pan...
My process is very silimar to rrush's, and the biggest benefit (from an exam standpoint) has been the separation of duties for entry vs verification. The FDIC has been much happier with our process since we split it up.
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#2068423 - 03/10/16 04:24 PM Re: How do you HMDA? B-Girl
raitchjay Offline
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Joined: Oct 2009
Posts: 8,727
OK
Ok...i see...thanks. Yes, i guess i am still trying to wean myself off my distrust of our LOS (my processors really).
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#2068436 - 03/10/16 04:37 PM Re: How do you HMDA? B-Girl
rrush Offline
Member
Joined: Dec 2011
Posts: 74
Accountability is a huge motivator. No one likes to have to spend time doing corrections, get it right the first time and the compliance officer does not "come calling". smile

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#2068553 - 03/10/16 09:21 PM Re: How do you HMDA? B-Girl
Carter'sMom Offline
Junior Member
Joined: Aug 2015
Posts: 38
1. Asset Size? 2.5 Billion
2. How many individuals do you have that is ultimately responsible for the verification of the HMDA data? 1-2
3. What department do these individuals report to? Credit - LOAN data
4. How many are in this department? 25

Compliance Review samples quarterly prior to filing
Internal Audit tests annually post filing

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#2069549 - 03/16/16 03:12 PM Re: How do you HMDA? B-Girl
Rules rule! Offline
Junior Member
Joined: Oct 2005
Posts: 44
Cincinnati, OH
We are a small community bank and file on average 130 LARS/year. We use our LOS to capture the HMDA information and import it to the FFIECs software at report time.

I pull a HMDA report every month and scrub it for errors and some qc. I also recheck at each quarter. ( We are going to start this year with an ongoing random pull of hard files so we can compare source data with the LAR). At the end of the year, I begin remind the loan officers to go thru all their drawers and I comb thru the application logs for comparison & any other possible additions. I do my HMDA pull and begin a scrub of it all line by line... looking for oddball entries and missing items. Once I have uploaded to the FFIECs software, it has its own little quality check. Once complete and checked over w/ my boss, I "pull the trigger" and submit it all.
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#2071473 - 03/29/16 07:54 PM Re: How do you HMDA? B-Girl
Winning Offline
Member
Joined: Sep 2015
Posts: 88
WOW! I am also the lone ranger here...and have been thinking of a solution for the new changes. As of present...don't have a solution. I wish there was a collection software out there that would capture info from the core..or ideally, the loan information at closing and deposit it for me into a LAR. That way, the processors are not manually entering it...the software would just grab the info out there (like loan amt., address, date of birth(age), etc etc) and populate it in the correct area.

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#2071475 - 03/29/16 07:59 PM Re: How do you HMDA? B-Girl
rrush Offline
Member
Joined: Dec 2011
Posts: 74
There is a software that does that. Questsoft has HMDA Relief. It gets the information from your origination system and runs all of the validity and quality checks. You then submit the LAR using their software. I could not imagine doing the reporting without it. The price is very affordable and saves me a huge amount of time.

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#2071476 - 03/29/16 08:01 PM Re: How do you HMDA? B-Girl
rrush Offline
Member
Joined: Dec 2011
Posts: 74
I would add we have around 400 to 500 entries in the LAR each year. I would still do it this way if I only had 100.

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#2071518 - 03/29/16 10:27 PM Re: How do you HMDA? B-Girl
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
Our LOS has an export feature; I have the Loan Processors screen-print 3 HMDA screens from the LOS,validate that data, sign off, and hand off to Compliance (moi). I review against source documents, make any adjustments, export from the LOS and import into CRA-DES. The LAR is built through time, so no major work is needed at quarter's end, other than reviewing against reports to ensure none are missed. I do that monthly. We are a commercial bank, so HMDAland can be somewhat crazy here since most loans are business related. At my prior bank, I didn't have to do as much; HMDA was primarily residential, and trained processors kept good control over the data - never had a problem with exams.

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#2071519 - 03/29/16 10:53 PM Re: How do you HMDA? B-Girl
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,928
Idaho
Our secondary market division LOS has an export into HMDA Relief, but portfolio loans have to be hand entered, which makes the addition of HELOCs in a few years really daunting. I scrub loans monthly against source documents, do omissions testing quarterly and a final scrub before submission. I'm pretty much a 1 man show other than a end of year review by our internal auditor. LARs have ranged from 650 to 1500 lines and we are 1.2 B in assets.
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#2071564 - 03/30/16 01:41 PM Re: How do you HMDA? rrush
Winning Offline
Member
Joined: Sep 2015
Posts: 88
We have had as many as 950 entries before...and I do it all by hand..and review every file, etc etc. There is NO WAY this can be done with the new changes coming.

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