I agree with you about the REMA. We have reviewed our HMDA loans to come up with our REMA, so we have at least a starting point for that, of course subject to the examiners' opinions. All of the purchased loans are outside our CRA AA. All of the purchased loans are also outside our REMA except 1. The 1 loan in our REMA is not in a low or moderate CT, nor is the CT a high minority CT. The loan is not to a low or moderate income individual.
Yes, we are omitting income.
No, I don't know what the GMI field content is at this time for all of the loans, although we have the applications and can get it for the HMDA LAR if need be. I was just trying to cut down on errors, and if none of the loans are in our AA, and only 1 in our REMA, I am not sure it is worth the extra effort, and I am not sure that it would really be considered during an exam if those loans are not in our AA. The 1 in our REMA might, but it's location does not help with LMI and high minority CT penetration.
Trying to keep HMDA clean but help CRA in any way we can. ???