Hi, have to post anonomously for obvious reasons -

We are a first time HMDA reporter this year - I am compliance officer - I gave the loan dept. training materials, etc. for HMDA and their supervisor had told me he had done it before -

Here's the problem - I asked how it was going today, and was told the loan dept. decided HMDA reporting was my job as compliance officer - they will try to give me the loan info, but I need to submit it, help the person put the list together, figure out how to send it and be the contact person. Are any other compliance officers out there actually doing the HMDA Reporting? I am in a panic and very upset about this - but don't want to make a fuss if I am wrong. I believe it is a loan function (like sending out disclosures, etc.)

PLease help!!!!!!!

thanks!

Well, gee, isn't that nice for them to let you know, now.

Our loan dept. (originations/underwriting) are responsible for maintaining and transmitting the data. As compliance, I perform the scrub for accuracy.

We compile the data, geo-code, scrub and submit from the Compliance Department. Our Loan Operations Department is responsible for coding the accounts properly. We do a lot of testing and monitoring throughout the year to ensure accuracy.

I encourage you to avoid the "them vs. me" stance that you could adopt if you fail to consider this a cooperative exercise. The loan department needs to provide the raw data on all the loans you will be submitting. They should have been recording those data all year long. You'll be offering guidance, of course, on how loans are to be coded as they are recorded.

You'll need the loan department's help when you review the data and find the inevitable errors.

Whether the loan department or you are the contact person isn't really critical, although I suggest you'll want to fill that role at least the first time around, so that you are aware of any problems your regulator has with the file.

I suggest you and the head of the department sit down and agree how you can cooperatively get this file "out the door" accurately and on time. You have about three weeks left!

I've seen it both ways. There is certainly no regulatory requirement for it to be one way of the other, just what works best for your institution. I personally think that having production responsible works best overall, because then you have another layer of oversight (the compliance officer), but it can work ok either way.

What obviously, clearly needs to be done is to have the decision made and communicated at the beginning of the process so that everyone knows their responsibilities and roles. And it should certainly not be up to the loan department to decide it's your job. That decision should be made further up the chain by someone that can weigh all the factors.

Having it dumped on you (or anyone!) 3 weeks before it is due is totally unacceptable IMO, and you need to elevate the problem as far as you can as fast as you can. If I were you, I wouldn't waste time at this point pointing fingers or figuring out what went wrong. You can do that after you've submitted. Make it clear to senior management that you will do everything you can to ensure a complete, accurate, on-time submission is made, but that you cannot do it alone. Also make it clear that this is something that will not be taken lightly by your examiners if you fail to meet the March 1 deadline. Your institution has had more than a year to get its act together, and they won't be giving you any grace just because it's your first year.

Unfortunately this should have been resolved some time ago by senior management or the board. I think in all banks the lending dpartment needs to gather the basic data from the applications and files. In some banks the compliance officer then gathers the data from the various lending departments, scrubs and submits it. In others, the lending departments do the data input and compliance does the scrub and submission. (You said just HMDA, what about CRA?)
With the time crunch you now have I suggest you sit down with the prez and head of lending and resolve exactly who is doing what to get through this year and then how this will be handled on an ongoing basis.
You need to take charge and get these decisions made or you are going to be the scapegoat.

...and I only found out because I asked how it was going - kind of scary to think when they would have told me if I hadn't mentioned it! I was also told the training I provided was too long as it was over an hour course! I don't mind helping if necessary, but helping and doing and being totally responsible are too very different things. I thought I always remembered loan dept doing HMDA...

Thanks for the input, I guess it can go either way. I will have to just get it done somehow - I just can't believe people would decide at the last minute that they are not going to do something they said they would take responsibility for - it's not a good way to do things. At least if I have to do it I will know ahead of time for next year.

It appears unanimous. Our loan servicing also inputs the LAR data. This way they can monitor and I (the Compliance Officer) can do the audit/scrubbing independent of the monitoring. It wouldn't be too effective to do my own input, monitoring and auditing, nor would it pass muster with a regulator.

One other comment - (On my soapbox): The loan dept should not be telling the Compliance Officer what they should be doing. Your level of authority should give you complete independence of anyone in the organization (i.e. you report to the Board of Directors) giving you latitude to correct this kind of deficiency. You really need the support of senior management on this (Off my soapbox).

-Chris

Loan processors input info then the Loan Certification Dept. enters on HMDA. Me, the Compliance Department, audits, so I cannot be invovled in the day-to-day activities.

We process scrub and submit a number of HMDA and CRA submissions and the data usually comes from the compliance officer or department. They are responsible for the accuracy of the data, and usually have a hands on process in the effort. It is more often likey than not, that compliance officer tell us they cannot trust Loan Officers or Loan operations departments, to accurately collect the data no matter how much training they receive.

Some institution use the government supplied software and manualy enter each loan throught out the year. The entry is also the time they scrub the fle.

Some choose to start the scrub process in December or January and this is probably OK if you don't have a lot of records to report.

Remember as the compliance officer you are going to be the one that is going to certifying the data is correct after its submitted. You cannot blame a rescrub on the other department.

It real late in the year to dump this on you and its 20 days to submission deadline. IMO don't get in a contest just now as the data has to get processed. This is a battle I recommend you fight after the submission and start getting the submission together.

If you e-mail or call I'll try and help get you started if you haven't done this before.

FWIW, we operate like Chris. The loan dept enters the info into the loan software. The system produces the LAR report. I (compliance) scrub it, download it into HMDA DES and submit it. The VP of the loan dept (my boss) is listed as the contact person.

First, I'd make sure my boss knew about this NOW!
Next, see if you can get a LAR off your loan system and then start scrubbing...hard!

Training (which I handle here so I know it's done right) and negotiating will have to wait until after March 1.

Thanks for the offer! I am going to ask for a meeting with senior management and see what happens. The problem is I am not only compliance officer I have several other titles so if I do it, it will be difficult at this point with less than a month 'til the deadline.

OK, as noted it may be done in whatever manner works. But what you have now, doesn't.

First, do you have any idea how many records are involved? That is a biggie.

Second, supervisor to supervisor (possibly with a higher-up to tie-break) there needs to be a meeting and an discussion. What was done is unacceptable, especially if you'll have a lot of records to worry about. Someone has to identify the loans and pull the records. Hopefully they don't have to pull all the records to identify the loans.

Take a deep breath, this is doable.

Sit down with the files and the LAR sheet or PC program and enter them, or use a program to download the data from your system. If the latter wasn't already in place, it may well be too late for this and you are in manual focus mode.

The other department should be doing this, per your agreement/understanding, and you verifying it. They may ask you to take it for 2005, but not 2004. I'd emphasize that this person said they'd done it before and they will be expected to live up to the agreement as they will be signing the sheet that says the data is correct. You should provide your assistance, but it isn't fair to the bank or you to have this dumped now.

(Tongue in cheek, you could also mention that you don't want this dumped on you because they'll then try to use this as an excuse to explain why they had such a poor rating on their next (fill in the bank) audit that you have scheduled for them, and again when this slob was supposed to be going on vacation.)

Part of a secondary plan is to remember that you have to submit by March 1. It need not be error free by that date as they will come back to you with edits and an opportunity to correct errors. So you have a little more time to "get it right" if absolutely necessary and you use the system a bit.

and I guess I shouldn't have let someone else take responsibility for something in compliance in the entirety -lesson learned

Thanks Andy

We are wrestling with a similar "responsibility" issue and I would like the opinion of others. Let's assume that loan dept inputs the data and they do the best they can with the info. that they are given. Compliance reviews the files and submits the HMDA and CRA reports. In the CRA report, the LAR ask for an income code, 1,2,or 3. Who, in your bank, is responsible for backing up this number? (as in examiners doing data integrity, etc.) The Loan Officer or the Loan Dept.?

We don't report CRA, but for HMDA the income reported must be documented/backed up by the loan officer.

When I came to my current Bank almost two years ago, a clerk with some training was performing HMDA data entry. This was after the Bank had been cited twice for HMDA deficiencies and errors in data reporting. I did extensive training, but found that the "learning level" of most of the loan officers and loan administration personnel was not high and errors in data reporting and in judgement about what was and wasn't HMDA continued.

So I took and retain complete authority over HMDA data collection and reporting, especially since the sweeping changes in 2004.

I wish that I could train someone to do this, but right now it is more important to have "clean" and complete data. It's also very hard to just give someone HMDA without adequate oversight for a considerable period of time to make sure they know the correct questions to ask when something doesn't look quite right.

The regulators are concerned about proper HMDA data collection and reporting, so if there's a mistake, I know that only I could have made it. That's why I double check my data entries quarterly and scrub the FFIEC HMDA Error Report in January yearly. I also work with the Bank's Internal Auditor to validate my procedures and annual audit.

I don't like having the Bank depend totally on me for HMDA knowledge, but with the past HMDA issues (including having to re-submit for two previous years), it's the way it has to be right now.

The loan dept inputs the data into the mortgage software (hopefully it was provided from the loan officer). We (the CRA dept) down load the loans into CRAWiz. Reports are given to the compliance dept and they do a review for accuracy. They are supposed to supply us with any missing info and correct anything that is wrong. My dept (CRA) does the submission for CRA & HMDA.

I have pushed for the loan dept to take a more active roll in obtaining missing info. If they are putting a loan in the system and info is missing, I want them to request it from the loan officer. Obviously this doesn't happen enough because we still receive down loads with empty categories. It is much better than it used to be.

As the chief lending officer, and the signatory on the HMDA report, I have always felt that the integrity of the data was primarily my responsibility. (BTW, original poster, who will be signing the HMDA report for your bank?) The LAR data is entered into the loan origination system by our processors, and updated by our underwriter and closers. Each month, I import the data into HMDA Relief and scrub. That way I can catch errors quicker, the files are "fresher" in everyone's mind, and I can correct any bad habits or misunderstandings sooner. With all the changes in HMDA this past year, I shudder to think of doing it any other way.

While this is a lot of work on a monthly basis, it makes the annual report submission almost anticlimactic. I have confidence in the accuracy of our data, and I can demonstrate to the examiners how seriously we take HMDA compliance.

Dear Anon,

As a vendor of HMDA software, your situation is unfortunately a much too common one, especially on the non-bank side.

We help people in your situation ALL of the time. Because your type of situation is more common that most people think, we have written our software specifically so we don't get overburdened by last minute orders. We typically sign-up 25-30 companies just during the last week of February (mostly mortgage bankers).

Our customers are generally up and running about 1 hour after we receive an order and know exactly the scope of their problems within about 15 minutes after installation. We are more than happy to offer as much free training as you need to get you started and familiar with the process. If fact, we are offering a promotion to finish in two days or it is free to save us from last minute submissions. I would welcome the challenge and for you to post your comments after use back to this thread.

Email me at len@questsoft.com or call at 800-575-4632 x-211 if you have any concerns.

Sincerely,

Leonard Ryan
President
QuestSoft

P.S. For everyone out there, I really try not to write promoting us over other vendors but this person seems to need help that we are in a unique position to offer so I hope all understand my self-interest expressed here. To be fair, Don could probably help too. But I don't think there are many companies out there that can turn on a dime like we can and help someone that has had this responsibility dumped on them at the last minute.

Thanks for mentioning me in your company plug Leonard. And Yes, I do a lot of this kind of work. My comment to call or e-mail however was ofered to help "without charge" getting the person some oganizational help with getting the project started, if they did not want to use an outside vendor.

Both Leonard and I are vendors who do this work for a fee. I am a retired banker who does provide some help and advice where I can, without starting a fee clock. Yes if you ask me to do the work for you I will charge a fee. Advice is free

Update from original poster -

Went to upper management who first of all agreed that officers are not in a position to determine what other officers duties are, however, did stress that we are on the same team. So we are going to pull together (not the original person who let the ball drop on this) and get it done somehow. As it turns out someone in lending has done HMDA several times before at another bank, as far as the forms go, - so all I will have to do is find out how to submit. Apparently, it should be a small volume of loans - so it shouldn't be too bad. I am prepared to help anyway I can (short of signing off on anything). After we get through this, procedures will be put in place as to clarify everyone's responsibilities next year so this doesn't happen again. Thanks for all the help and tips on how to handle this - I was in a total panic! The solution we came up with wouldn't have happened without your help. Thanks a million!