Does anyone remember a time when the FDIC would impose a fine on a bank if it was found their CRA data was not accurate? The current exam manual doesn't say anything about it now but a colleague seems to remember once upon a time this did happen.

I can not specifically remember an actual CMP issued, but you can be ordered to do a data integrity scrub and the cost of that can far outweigh the threat of penalty.

In theory any regulation could result in a CMP based upon each regulators statutory authority to assess penalties. To have that happen it would have to meet the criteria used by each agency which involves a number of factors, most which would be unlikely to fit a CRA data issue. If you intentionally and willfully attempted to manipulate your data? Sure, that could do it.

HMDA CMPs were a thing. Maybe that is what your colleague is thinking about?

The only time I encountered something like this was when a bank was told they had 30 days to resubmit their file (which had some major errors in it which were discovered as examiners scrutinized their data in preparation for an exam). If they didn't clean up the mess (it involved 3 years of misreported data) they would fail their exam and the EIC would criticize the CEO in a board session.. You should have seen the CEO's response. It was just before Christmas and everyone had to work through 2 weekends to scrub and clean the data and resubmit it before the deadline. I never saw a more motivated CEO. It would be very embarrassing to any CEO to be criticized in front of the Board for something as basic as failing to report accurate data. They retained us to oversee the project. And the resubmitted data was error-free.

I haven't seen fines, but I have seen MRAs and MOUs for bad CRA data. I've seen regulators require banks to hire outside consultants to help them fix problems in CRA data too.

The CFPB has issues civil money penalties for bad HMDA data.

I have not seen any fines, but as others have said, demands to fix and resubmit at a quick pace are common, as well as MOUs.

Thanks all. I agree with all the comments regarding how bad it is. We had someone who thought she remember a fine but was confusing it with the HMDA data.