Thread Options
|
Tools
|
#69581 - 03/25/03 04:03 PM
HMDA LAR
|
Anonymous
Unregistered
|
I just discovered that my institution has been filing incorrect data on the HMDA LAR for the past 5 years. Do we need to re-file? If so, for how many years back? Also, do penalties apply. The problem appears to be due to ignorance and not malicious intent. I just joined the organization 10 months ago and just discovered the error.
Pease advise!!
|
Return to Top
|
|
|
|
#69582 - 03/25/03 04:15 PM
Re: HMDA LAR
|
10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
|
You may need to discuss it with your regulator. I don't believe there will be much gained from resubmissions from years gone by, but 2002 may be another story. Also, if your HMDA is to be used or was used in a CRA exam, there could be implications there, depending on the errors.
Are they at the 10% mark for resubmission?
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#69583 - 03/25/03 04:21 PM
Re: HMDA LAR
|
Platinum Poster
Joined: Mar 2002
Posts: 721
California
|
Quote:
I just discovered that my institution has been filing incorrect data on the HMDA LAR for the past 5 years.
Do you mind if I ask what kind of errors and was this not picked up from any past audits?
|
Return to Top
|
|
|
|
#69584 - 03/25/03 04:27 PM
Re: HMDA LAR
|
Anonymous
Unregistered
|
The error was not picked up previously. The error invloves the coding of Withrawns, counteroffers and conditional approvals. It appears that many conditional approvals that should have been coded as a decline were coded as an approved not accepted, ditto for the counteroffers that did not close.
|
Return to Top
|
|
|
|
#69585 - 03/25/03 04:29 PM
Re: HMDA LAR
|
Anonymous
Unregistered
|
The error is that we have a very high percentage of approved not accepted loans in the LAR and a very low percentage of declines. I beleive that it does exceed the 10% threshold for these two types of action taken codes.
|
Return to Top
|
|
|
|
#69586 - 03/25/03 05:48 PM
Re: HMDA LAR
|
Anonymous
Unregistered
|
If you are talking about Quality Errors, don't resubmit.
If you are talking about Validity Errors, don't you have some software that helps you find and fix?
|
Return to Top
|
|
|
|
#69587 - 03/25/03 06:34 PM
Re: HMDA LAR
|
10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
|
These are errors in key fields. It really doesn't matter that it is a Quality or Validity error, wrong is wrong and a 2002 resubmission may be needed. The error codes won't pick it up because it appears to be correct, but isn't.
Correction of prior years may be needed, at least internally if this will be used in CRA. My first call would be to the HMDA Help Line, my next to my examiner, both AFTER briefing management.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#69588 - 03/25/03 06:52 PM
Re: HMDA LAR
|
Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
|
It all depends on the applicant information as to having a Fair Lending issue, but changing records from, Approved not Accepted, to Decline, has a Fair Lending impact.
It would be prudent to see what type of impact this change in Action Taken will have on your decline data, with regards to tract income classifications, race and gender issues. It may not have any at all, but you need to take a look.
I would recommend you refile your 2002 data now. As Andy suggested how far back you may have to go is something you would check with your regulatore on.
_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs
|
Return to Top
|
|
|
|
#69589 - 03/25/03 07:07 PM
Re: HMDA LAR
|
Power Poster
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
|
http://www.occ.treas.gov/ftp/bulletin/2000-35a.pdfAs Andy and Don mentioned, resubmission of the 2002 data is probably a good idea (I'd do it if I were in your shoes) but you MUST be sure management is with you on this! Sending it in now, verses being asked to do an entire scrub is a wise decision. For future issues, you might want to check out the website I just posted. These are the OCC's guidelines for examiners and they include a data integrity test. Outlined are the areas they consider to be significant, and the guide for allowable errors. Since you've already determined you're over 10%...you're understanding that this is significant is great. Many would hide and hope it didn't bite them in the bumm in the future. As to the other years, the determination on their impact in your next exam is a key issue. If your HMDA data is reviewed, and you know it to be in error, you should at least consider resubmitting the data for the period of your next exam. Going back further would be a waste of time. Speaking with your examiner on this issue is a must. If they know you're going to clean up the data prior to their visit they'll give you some credit for your diligence. Good luck!
_________________________
Dawn Coursey VP/CRA Queen
CRA Rating is in...Oh who cares...I'm home with the baby.
|
Return to Top
|
|
|
|
#69592 - 03/25/03 09:57 PM
Re: HMDA LAR
|
10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
|
Yes there will be new LARs and codes, etc. Your software vendors and mainframe folks (if applicable) need to be working on this as we "speak". The Fed is gathering comments now on how to handle the transition for apps gathered in 2003 and closed in 2004, as an example. So while all the questioned are not answered, there is sufficient data to start the early changes that are needed.
On the other hand, you do not want to "release these changes into the wild" yet because they cannot be used at this time. We'll do training late in the year.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
|
Return to Top
|
|
|
|
#69593 - 03/25/03 10:28 PM
Re: HMDA LAR
|
Power Poster
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
|
Personally I'm going to join the circus in 2004. It sounds as wackey as the new HMDA collection requirements, and you get all the peanuts you can steal from the elephants. Training will be a key, but I'd agree with Andy, it's not time yet. I refuse to talk to the IT department. I'll just hide my head in the sand and hope they figure it out (ok i'm kidding!)
_________________________
Dawn Coursey VP/CRA Queen
CRA Rating is in...Oh who cares...I'm home with the baby.
|
Return to Top
|
|
|
|
|
|