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#1627161 - 11/10/11 04:04 PM HMDA Examination
More Changes?!? Offline
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Joined: Dec 2007
Posts: 98
Getting ready to go through my first HMDA exam by our regulators. Any advice, tips, things they really concentrated on?

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HMDA

   
HMDA Academy
#1627167 - 11/10/11 04:06 PM Re: HMDA Examination More Changes?!?
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Data integrity (error rates) are key. They also want to see training and procedures. If the exam is starting all you can do is react, and begin to prepare for next time.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1627398 - 11/10/11 07:09 PM Re: HMDA Examination Kathleen O. Blanchard
More Changes?!? Offline
Member
Joined: Dec 2007
Posts: 98
ok question regarding applications just looking at some old loans.. have a loan made in 2009 for refinance of property, the application listed on the 2009 LAR is a date from 2007(the orginal purchase of the same property). Is this allowed? WIth all the changes I cant think back that far!

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#1627406 - 11/10/11 07:15 PM Re: HMDA Examination More Changes?!?
raitchjay Offline
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Joined: Oct 2009
Posts: 9,108
OK
I don't see how the original application date for the purchase of the property can be the correct application date for the refinance of the same property. I'd be looking to correct that.
_________________________
I'm fixin' to fix that.

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#1627474 - 11/10/11 08:01 PM Re: HMDA Examination raitchjay
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,400
The date is incorrect as reported for HMDA but you shouldn't go back and correct it now. Don't touch anything that has already been submitted.

If this is just an odd needle in your HMDA haystack maybe it won't even be found or at least it will viewed as just a single error. You need to worry about what HMDA examiners call 'pattern and practice'. If you consistently have application dates reported erroneously, then you're going to have a problem. But again, it's too late to fix what has been submitted unless you're make to do a resubmission by the examiners.

All that said, if your review now finds a pattern & practice, write it up and train like crazy so you can present that to the examiners. Being proactive is looked upon favorably during exams.

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