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#436345 - 10/06/05 04:21 PM CRA and HMDA - double reporting
DebbieC Offline
Joined: Jul 2001
Posts: 66
Owensboro, KY USA
I've been told by our CRA Officer that it is appropriate to post refinances on both the HMDA and the CRA LARs(double reporting)due to the 2004 changes in the way we look at refinances. Is this true?

If so, were can I find information in the regulations that support this. Thanks

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Lending Compliance
#436346 - 10/06/05 04:58 PM Re: CRA and HMDA - double reporting
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,016
Bloomington, IN
Do a search in the CRA and Lending Compliance forums using "double reporting" and you will find several threads discussing the issue.

Here's one to get you started.
The opinions expressed are mine and they are not to be taken as legal advice.

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#436347 - 10/06/05 06:10 PM Re: CRA and HMDA - double reporting
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Just for clarification....there is no such thing as a CRA LAR. For CRA you submit an LR and for HMDA you submit an LAR.

You can record all the loans on your CRA LR that you wish to, but for the actual submission, only type 1 and 2 loans will be submitted, which means you're wasting time entering type 3 loans (secured with residential collateral that is not multifamily). If your CRA officer wants these tracked (I track everything) go for it. If you are doing a great deal of hand entry, and don't need the type 3 deals during exam, don't bother.
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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