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#2255203 - 06/11/21 07:59 PM HMDA - 1003.4 (f)

Does the compilation of reportable data at the end of 30 days after the previous quarter have to be scrubbed? Or does a bank just need to have the data available....albeit some fields may be incorrect. Any help would be appreciated.

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#2255204 - 06/11/21 08:08 PM Re: HMDA - 1003.4 (f) Anonymous
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,408
Cape Cod
Recorded on a LAR in any format (paper, electronic), and it can be separated by branch or product or whatever, buf it must be available to your regulator in a timely manner on request.

That doesn't say it has to be scrubbed. But I don't think it should be so full of errors that it's not of any use, either.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2255208 - 06/11/21 08:32 PM Re: HMDA - 1003.4 (f) Anonymous
rlcarey Offline
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Joined: Jul 2001
Posts: 77,591
Galveston, TX
It will depend on whether or not the regulator thinks you have made a good-faith effort. The number of errors identified might make that determination for you.

1006.3(b)(3) If an institution makes a good-faith effort to record all data concerning covered transactions fully and accurately within thirty calendar days after the end of each calendar quarter, and some data are nevertheless inaccurate or incomplete, the error or omission is not a violation of the act or this part provided that the institution corrects or completes the information prior to submitting the loan/application register to its regulatory agency.
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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