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#2154466 - 11/21/17 08:12 PM Resubmit HMDA
Likes to Comply Offline
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Can HMDA data (2016) be resubmitted using the FFIEC HMDA Data Entry Software - Submission via Web?

FAQs say it can, but the link to the Data Collection Procedure Change only mentions via e-mail, CD-ROM, or diskette...

Thanks in advance for you help!
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#2154513 - 11/22/17 03:01 AM Re: Resubmit HMDA Likes to Comply
Truffle Royale Offline

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Why are you resubmitting? Unless it's by examiner order, in which case they can tell you how to do it, I cannot understand why you would be trying to resubmit now, a year afterwards.

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#2154524 - 11/22/17 12:41 PM Re: Resubmit HMDA Likes to Comply
Adam Witmer Offline
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Likes to Comply: I would just contact HMDA and ask them. My guess is you will use the old system as the Fed was responsible for 2016 data and the CFPB is responsible for 2017 (and beyond) data.

Truffle: If a bank knows of a systemic error - or even several errors - and their regulators have yet to review their LAR, why wouldn't they want to voluntarily resubmit? I always thought the consensus was that if you know of errors, it is better to resubmit voluntarily than to wait for examiners to tell you to do it. Just wondering if I am missing something.
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#2154533 - 11/22/17 01:45 PM Re: Resubmit HMDA Likes to Comply
Likes to Comply Offline
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We did already speak to our examiner and they were in agreement with us voluntarily re-submitting. I'll just contact them again to see if I can do so using the FFIEC Software.

Thanks.
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#2154539 - 11/22/17 02:11 PM Re: Resubmit HMDA Likes to Comply
Adam Witmer Offline
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I don't think you need to contact your examiner. I would contact hmdahelp@frb.gov to ensure resubmissions of the 2016 data come through them. I am pretty sure the Fed should be handling resubmissions of 2016 data, but I would double check that with them.

From the small entity compliance guide:
Technical questions about collecting or reporting 2015 and 2016 HMDA data (reported in 2016 and 2017) should continue to be directed to hmdahelp@frb.gov or 202-452-2016. Technical questions about collecting HMDA data for 2017 and later years or reporting HMDA data in 2018 and later years should be directed to hmdahelp@cfpb.gov.
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#2154684 - 11/22/17 08:40 PM Re: Resubmit HMDA Likes to Comply
Likes to Comply Offline
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LOL...the number has a message that says to email...
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#2154705 - 11/23/17 12:03 AM Re: Resubmit HMDA Likes to Comply
Moman Offline
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Just went through a FED exam - we discovered a few loans where we used 2 for the preapproval code rather than 3 (NA). We re-submitted and provided an updated register with our exhibits - the FED didn't question it this round - never asked for an explanation, just did their data validation from the new data provided.

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#2154717 - 11/23/17 09:24 PM Re: Resubmit HMDA Adam Witmer
Truffle Royale Offline

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Quote:
If a bank knows of a systemic error - or even several errors - and their regulators have yet to review their LAR, why wouldn't they want to voluntarily resubmit? I always thought the consensus was that if you know of errors, it is better to resubmit voluntarily than to wait for examiners to tell you to do it
What consensus? I've never heard this as a recommendation.

If you identify an error and correct it and can show an examiner the trail, then I don't see the point to resubmitting. If you have several errors, you'd best be able to show how you found them, the training you've done to correct it and your current LAR being correct. The examiners I've dealt with want to know that I'm doing it right now rather than I can hit the button on the old stuff. Besides, once you're past the cut-off, fixing the errors is the equivalent of writing 100x on the blackboard. Your corrections are not reflected in the aggregate data.

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#2154782 - 11/27/17 02:37 PM Re: Resubmit HMDA Truffle Royale
Adam Witmer Offline
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Originally Posted By Truffle Royale
What consensus? I've never heard this as a recommendation.

Well, I guess I was referring to the consensus of bankers and examiners I have talked to over the years. I have heard story after story that is consistent with what Moman said: They voluntarily resubmitted before their exam and their regulators never questioned the resubmission and also conducted their HMDA validation based off the resubmission (new) data.

Originally Posted By Truffle Royale
Besides, once you're past the cut-off, fixing the errors is the equivalent of writing 100x on the blackboard. Your corrections are not reflected in the aggregate data.


A seasoned FDIC examiner once explained to me (which I later confirmed with the FRB) that resubmitted HMDA data would be corrected in the (nationwide) aggregate file up to about 2 1/2 years after the original submission date. While they would not update the bank's individual HMDA reports, the aggregate data is still updated - which is exactly why the regulators make banks resubmit HMDA data from a year or two ago.

In the past, HMDAHelp even gave me an exact date (about 2 1/2 years after the original submission deadline) for which resubmission data would no longer be added to the aggregate file, meaning that I had to get my voluntary resubmission in before that date.

My understanding is that the bottom line is that if you don't voluntarily resubmit, the examiners review the original data that has known errors and the bank risks a cited violation as well as a forced resubmission.
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#2154810 - 11/27/17 03:49 PM Re: Resubmit HMDA Likes to Comply
Truffle Royale Offline

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Which brings us back around to my original question which started my line of thinking.
If a bank finds a systematic error that permeates their LAR, then I agree they should resubmit.
I'm assuming that's what happened from Likes To Comply's post stating they'd discussed this with their examiner.

My point is that I have heard of too many banks that find an off error or two and panic and think they have to resubmit.
Having been through many a HMDA exam myself, I stand by my statement that self-identification and training will be sufficient to appease examiners in this type of situation.

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