Wow JSD.. I can't even imagine. I'm assuming you have a rather sizeable staff responsible for this information already, correct?

I concur with both of you. Bank's better have fair lending issues identified and have a plan in place to address any gaps in lending or performed reviews of pricing disparities before the examiners arrive. HMDA is just the tip of the iceberg.

Originally Posted By Third Trip

As of now, no new employees.

1.1 Billion
2015 LAR- 550
Estimated- 1000-1100

And not to hijack this thread, but curious as to where the HMDA function resides within your organization; business line or compliance. By that, I mean, who is responsible for the final scrub, consolidation and submission.


Not hijacking at all Third Trip - certainly a valuable part of the conversation.

Currently the department conducts an internal (first line) review but there is not a true HMDA person. The responsibility is shared between UW and other staff and error rates have hovered around 10% over the last year. Unfortunately because of that I have to conduct 100% review which takes up a very considerable amount of my time. We are hoping to have staffing for a true first line of defense in the departments so we can conduct a true second review and sample. Right now I'm essentially the first and last line of defense... which is the WRONG way to do it. But if I don't do it, it wont get done and we will have time bombs for the next exam.



welcome to BOL by the way!

We do not have the staff that peers our size do - we are very small group of 4...

Wow JSD.... you must be superhuman. That's insane!!

Submission time is a crazy world around here!!!

JSD, do you mean there are four of you doing HMDA all year or ...?

Yes! That is the total FTE of the HMDA Unit at this FI.

None at this point. We do most of it manually, there are two of us. We are the only compliance officers for our bank.
We are $262 M
2015 LAR-estimate 350-400 entries

Four people working on HMDA year round makes the numbers you quoted a tad more manageable, imho, JSD. Still overwhelming at submission time but you've had all year to scrub as you go, right?
Most of us are dual purpose compliance/HMDA and don't get to just focus on HMDA.
I should think 2018 is going to force a lot of us to go the way your bank has with devoted personnel.

I would guess that JSD's bank has business units held accountable for submitting clean data because that size LAR wouldn't be manageable otherwise. I do not know the process but I have worked at institutions with LARs that size and each business unit was responsible for managing its data, running error reports, testing, etc. and it was then submitted to a central corporate group that combined it all and ran additional testing. So, staffing needs trickle down to the business lines as well as the corporate group.

Yes you are correct Kaybee! The first line of defense is each line of business (LOB) as it is their responsibility to capture and pass accurate data. Within each LOB internal HMDA reviews are performed. Within our group of 4 we do our own monitoring for each LOB typically quarterly. Then Audit performs their work annually. We do a large amount of consulting with each LOB daily. We have one technical person who imports the data, manages the edits and gets LAR data ready through a software program. There are many checks and balances performed along the way by all who touch reportable loan files. The new requirements are very challenging as we are in the process of changing many of the operating loan systems at the same time of configuring the new 110 data fields. It is always a challenge with regulation changes for a bank this size - it is not easy to get this ship running in a different direction as the CFPB wants!

I used to have an employee when I managed Credit Policy and Procedures at a large bank who would tell Legal, when they would wanted a last minute change (without legal impact), "We can't turn this ship that quickly. We will get your change at the next update."

Thank you JSD and KayBee!

Currently they are not approving an addition of any new employees for this. I have suggested 1 at minimum just to help with our current reviews that we in Compliance perform.

Thank you Banker K. May I ask the size of the institution & LAR?

Thanks!

@ Darth HMDA,

Yes, we are just over $500Mil and our LARs have averaged 1,200 entries with our in-house and secondary market combined.
We don't anticipate a huge increase in records being added in 2018 with addition of revolvers because we will be losing many of our smaller in-house "home improvement NOT secured by RE" loans in exchange in 2018.

However, the audit time will significantly increase since essentially the fields to be checked will triple, so I definitely believe we need at least 1 more person to help with internal audits.

Ya, ours will be 0. It's still going to be just the 1 person...me. And I do the denials and withdrawls, plus I do real estate loan review!

Our Asset size is 435 million
2016 LAR so far is 557 through Sept reporting, probably ending with around 700+
Estimate increase of reporting will be another 200+

And no plans to hire another FTE, it's just going to be myself.

We're about the same size and no. of LARs. Our LARs have declined since 2012 despite having a full blown mortgage department that other banks 10X our size do not have. These changes should not be applicable to small institutions which should be granted a small creditor exemption from HMDA altogether. PERIOD. How meaningful is this data of a small community bank reporting less than 200 LARs that's doing all it can to compete with the MEGA BANKS in its community. One size fits all regs do not fit any longer. We need a change! Oh wait!!

We are adding none....I'm it! Just me....I am feeling so overwhelmed right now!! I'm finishing up 2016 and going to be submitting 2016 and all this new stuff in my head at the same time is about to give me brain overload!!!

Thank you for responding Catm. May we ask the size of your current LAR and your estimated size of the 2018 LAR (if you are aware).

I'm sorry to hear you are on your own... Jan/Feb are always a challenge for those of us who deal with HMDA. Believe me I understand. I wish you the best of luck!!

Current LAR is 684, and estimated size for 2018 is estimated to be well over 1500.

thank you for sharing Catm.