I was wondering what other banks use as the identifying number as a unique number without sacrificing privacy issues. The instructions state not to use the name or social security number. Do you just make up a dummy number and cross reference that to a borrower? We are having a little trouble keeping these straight as we have been adding branches and want to start having branch personnel enter LAR's at their branches and import to the home office.

Does your loan department have a file numbering system? That's what we use as the identifying number for HMDA. Ex: next application in the door will go into file no. 42875. The one after that is 42876. The numbers just keep going on and on. That's the # used to identify the file on the loan system and it carries over to the LAR.

Yes, we have a numbering system but were also concerned that this may present a privacy issue if that number would get out?
Also what do you do for denials where no loan number would exist?
Thanks for the reply.

We use a unique identifier which consists of the Branch location 2 letter abbreviation and a number after....ex. PE1, PE2, AW1. We put all of our data into a master file in excel which includes information not entered on the LAR so that if the examiners ask about PE1 we know that corresponds to loan 111222333 for John Doe.

We have a ledger book in which we record every application in numerical order. Those application numbers are the application numbers in the LAR.

When a loan closes, it is assigned the next number on our servicing system, which bears no relationship to the application numbering system. If a loan does not close, it is not assigned a loan number.

Currently, we use the loan number assigned if it is originated or purchased. For denied, withdrawn, etc. we keep a spreadsheet with numbers to be issued for that corresponding application (2007-1D, 2007-1W, 2007-1ANA). We only have about 200 LAR entries each year so it's easy to keep up with them.

Has anyone been critizied for using the actual loan number due to privacy issues?

We use the loan number for the identifier. I really don't see a privacy issue as the loan identifying numbers aren't printed on the public disclosure.

We have a manual system for non-originations. We use a four digit number starting at 1001 preceded by 02- for Approved but not accepted, 03- for denials, 04- for withdrawn and 05- for files closed for incompleteness.

Each lending customer has a number assigned to them, so we use the customer number and add the note number, i.e., 12345 78910. To distinguish a commmercial loan from a consumer (personal) loan we begin the number with a series of letters CL for commercial, PL for personal then add the loan officers three initials. PL LMN 12345 78910.

Denials are distinguished differently. The first letter designates what area the loan application was received from, M for Mortgage, P for Personal, C for Commercial. The next is the application number, then the first four letters of the applicant's last name, then a file number. It would look something like this - P 11892 MATT395.

I know this seems like a great deal of work, but it makes finding the file a snap. And when you have 2,800 HMDA entries and over 3,000 CRA entries, well, you get the picture.

I want to second Dan's comment about the "Privacy" issue. If your HMDA LAR gets out, you have some serious issues. This shouldn't be a factor in how you assign the application/loan # because it will NEVER get out.

I encourage banks to use as friendly of a system as possible. If you do auditing of the LAR, you know how hard it is to locate a specific line item if the LAR is numerous pages. Therefore, I suggest banks use the actual loan number followed by the applicant's/borrower's last name. Again, this isn't a privacy issue, because this info. isn't going to get out. Why not make this as easy as possible for yourself, your auditors and your regulators?