If a non-reportable loan is reported on the LAR, is every field considered to be an error? Or is is reviewed for accuracy and assuming no coding errors, 1 error is assigned because it does not belong on the LAR? Does anyone know how this works?

I've never had any experience with being dinged for a non-reportable loan. My experience with LAR errors leads me to believe that examiners would be more concerned with errors on truly reportable loans. Chances are it might never be found anyway unless there's a glaring neon sign pointing it out. jmho tho.

"Chances are it might never be found anyway unless there's a glaring neon sign pointing it out. jmho tho."


We saw an error in a legitimate loan once that either the software missed, or ignored the warning. Community bank reported a $330K loan as $330,000,000. Didn't use thousands - reported the whole thing which placed the loan at half of the asset size of the bank. They refiled. .

I believe it would be considered an error in each key field if it was selected in the examiner's sample. I don't know why they would review it for accuracy. Not sure how the could even make it count as 1 error as exam guides are based on errors per field.

HMDA transaction testing can be divided into two stages. Both stages test for errors only in individual
data fields that are selected for review as provided above in paragraph 4. In Stage 1, examiners review
only a subset of the sample (Initial Sample). The size of the Initial Sample will depend on the size of the
financial institution’s HMDA LAR, as shown in column B of the HMDA table. If the number of errors
identified in the Initial Sample falls below the Initial Sample Threshold in column C of the HMDA table
for each and every data field reviewed, no further sample review is required and the examiners may
conclude the transaction testing. If the number of errors in any data field reviewed equals or exceeds the
Initial Sample Threshold in column C of the HMDA table, examiners should proceed to Stage 2 and
review the remainder of the Total Sample. In Stage 2, examiners must review all data fields that had one
or more errors in the Initial Sample and may review any or all Initial Sample data fields reviewed and
found to have no errors in Stage 1

[i[I believe it would be considered an error in each key field if it was selected in the examiner's sample. I don't know why they would review it for accuracy.[/i]

I would agree. If the loan is not a covered loan then reporting the information for that loan would be a reporting error, in addition you may have other regulatory violations for collecting information that should not have been collected.