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#294094 - 12/28/04 05:10 PM
HMDA and CRA RANT
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Power Poster
Joined: Sep 2004
Posts: 4,241
middle of the country
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I just need to rant for a moment!!! I am working on the year end HMDA and CRA LAR reports and am trying not to blow a gasket. I have staff members from a number of departments that provide me with the HMDA, HELOC CRA and CRA input packets for the year end reporting. These staff members have been trained over and over and over and over again this year!! I give each department one list of missing files and one list of files with income clarification needed. These lists are clearly titled!! What do I get today but income clarfication files submitted as new LAR files and duplicates of those LAR files I already have!! What a waste of my time and their time. The training clearly gives the order of the information needed and yet the input packets come to me incomplete, one out of every 5 sometimes!!!  This is not rocket science or brain surgery, it really is easy stuff, just follow the specific directions given during the training. How is that so hard??? These are not dumb staff members either. The Chicago FRB will be here the week of March 14th for a data integrity audit and I need to get this right!!  Ok, I'm better now and can get back to the issue of getting CRA WIZ back up and running so I can get this done. Thanks for listening 
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#294099 - 12/28/04 06:05 PM
Re: HMDA and CRA RANT
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Power Poster
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
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This is why we have BOL - the support group for Compliance Officers!
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#294100 - 12/28/04 06:56 PM
Re: HMDA and CRA RANT
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Anonymous
Unregistered
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Quote:
I just need to rant for a moment!!! I am working on the year end HMDA and CRA LAR reports and am trying not to blow a gasket. I have staff members from a number of departments that provide me with the HMDA, HELOC CRA and CRA input packets for the year end reporting. These staff members have been trained over and over and over and over again this year!! I give each department one list of missing files and one list of files with income clarification needed. These lists are clearly titled!! What do I get today but income clarfication files submitted as new LAR files and duplicates of those LAR files I already have!! What a waste of my time and their time. The training clearly gives the order of the information needed and yet the input packets come to me incomplete, one out of every 5 sometimes!!! This is not rocket science or brain surgery, it really is easy stuff, just follow the specific directions given during the training. How is that so hard??? These are not dumb staff members either. The Chicago FRB will be here the week of March 14th for a data integrity audit and I need to get this right!!
Ok, I'm better now and can get back to the issue of getting CRA WIZ back up and running so I can get this done. Thanks for listening
This is not being realistic.
You are acting as though HMDA, goecoding, and conducting an analysis of the geographic distribution of bankwide lending is somehow more important to a Board than, say, capital, liquidity, the allowance, earnings, market sensitivity, and on and on.
C'mon. This is HMDA. These people that you talk about having trained...if they don't report directly to you, then it's obvious why there are problems. They are getting mixed messages from their supervisors, who are probably telling them -- in private -- that HMDA is a big waste of time.
You have to tackle the issue at a much higher level. You need to get more senior-level people committed toward promoting the correct processing. You also need to give them feedback once each quarter's HMDA results are known. Provide them with answers to questions, such as: "How many loans have we made to low- and moderate-income borrowers this quarter? Is it more or less than last quarter? What are our trends like? Are we lending at the same level to low-mods as our peer institutions?"
Ranting about how HMDA is not being seen as exciting and useful to others outside of CRA/HMDA/compliance is like a dentist complaining about how people are never happy and joyful when they visit the dentist's office. You've probably already figured out that people don't respond to threats of ratings downgrades and examiner crackdowns, etc., etc. Instead, you have to figure out how to make the HMDA processing provide true value to your organization -- such as by providing the business units with feedback on lending trends. Without doing that, you'll forever be ranting -- and all of the consultants combined will not help one bit.
With the new CRA and HMDA threshold changes, it's going to make the job tougher, not easier.
Consider this as having gotten free feedback from a consultant. You don't need to hire more to tell you the same thing.
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