Checking to see what you have for CRA/HMDA/Fair Lending staffing, and whether or not you are increasing due to 2018 changes. I know that there have been a couple of threads specific to HMDA, but I'm wanting more than HMDA. I'm particularly interested in the info for banks over $1 billion who are large bank CRA reporters.
- Size of Bank
- # of CRA Staff
- # of CRA LR entries
- # of HMDA staff
- # of HMDA LAR entries
- # of Fair Lending Staff
Be as detailed as you like. For us:
$1.8 billion in assets.
We have 1.5 staff who handle CRA, HMDA, and Fair Lending. What this means is we have a full time officer who imports all of the data into our CRA/HMDA/Fair Lending software from various systems, then scrubs the data throughout the year. She also prepares and presents reports of this data quarterly to Compliance Committee. Annually she does a full fair lending and CRA self-assessment of the data. Finally, she does the annually reporting. We have a person from another dept who helps part-time with the HMDA scrub. For mortgage, we have and in-house dept as well as a secondary market dept (we pull the data from those systems).
CRA LR: approx. 1600 entries
HMDA LR: approximately 1100 entries
We are still crunching the numbers, but anticipate a fairly significant increase in HMDA LAR entries with the 2018 changes, and we will not be adding staff (as of right now).