Hello. We are a large bank--about $7billion in assets. We use CRA Wiz software. Can anyone share what kind of HMDA & Small Business Loan data reports you present to Executive Management or the Board on a quarterly basis?

You should be reviewing the lending tests results and compare to the market and community-driven standards. You should be reviewing all community development activity You should present to the Committee information about data integrity. Finally, at least annually you should review your AA delineation and confirm no change is needed or recommend a change clearly articulating the reasons for your recommendation.

Thank you for your response. HMDA and CRA Public Data comes out once a year. Do I compare our quarterly lending tests results to a whole year of HMDA and CRA aggregate data?

Yes - the benchmarks are established annually. You must use the market data from the previous year as you proceed through the following year. Once the previous year's data has been released you can go back and review your performance for that year and compare it to the market data for that year. Typically the "penetration rates" don't change much year to year (although they can change for any individual lender). It is really sad that the Fed doesn't turn around the previous year's market data until December of the following year. The CFPB turns around the HMDA data before the end of May, which makes the Fed's record with the CRA data all the more shocking.

Thanks, Len.