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#1791819 - 03/06/13 02:50 PM HMDA file/data stored where?
Trees Offline
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Joined: Apr 2005
Posts: 4,013
We print out the HMDA data and keep it in a file at our main office branch ready for public request for it. Never requested thus far. The file is monstrous in size. Couple questions:
1. Any issues with having the res mortgage dept. keep the data rather than the main office branch? Same building.
2. What are your practices regarding these reports?
Thanks.

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#1791832 - 03/06/13 03:00 PM Re: HMDA file/data stored where? Trees
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
Are you talking about the Dislcosure or the actual data file you trasmitted to the FFIEC?
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#1791837 - 03/06/13 03:14 PM Re: HMDA file/data stored where? Trees
Truffle Royale Offline

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No it doesn't need to be instantaneously available. No walk-ins ever request mine either. I keep a printed copy of the LAR in a binder in my desk. The sign about it's availability is at the reception desk.

If you search way back in this forum, you'll find that the requests reported here were made via email for electronic files. The conclusion reached was that paper copies could be given rather than electronic in order to prevent manipulation of your data.

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#1791842 - 03/06/13 03:22 PM Re: HMDA file/data stored where? Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Just a comment on the data. Anyone can scan paper copies and convert to Excel. Also, later in the year, the government freely issues software with every LAR filed in downloadable format for analysis.

For CRA, your HMDA disclosure statement must be in the public file (not the LAR, although many put the LAR as well).

Rules for LAR disclosure, contained in HMDA, state:

(c) Public disclosure of modified loan/application register. A financial institution shall make its loan/application register available to the public after removing the following information regarding each entry: The application or loan number, the date that the application was received, and the date action was taken. An institution shall make its modified register available following the calendar year for which the data are compiled, by March 31 for a request received on or before March 1, and within thirty calendar days for a request received after March 1. The modified register need only contain data relating to the MSA or Metropolitan Division for which the request is made.

(d) Availability of data. A financial institution shall make its modified register available to the public for a period of three years and its disclosure statement available for a period of five years. An institution shall make the data available for inspection and copying during the hours the office is normally open to the public for business. It may impose a reasonable fee for any cost incurred in providing or reproducing the data.

(e) Notice of availability. A financial institution shall post a general notice about the availability of its HMDA data in the lobby of its home office and of each branch office located in an MSA and Metropolitan Division. An institution shall provide promptly upon request the location of the institution's offices where the statement is available for inspection and copying, or it may include the location in the lobby notice.
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HMDA/CRA Training/Consulting/Mapping
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#1791852 - 03/06/13 03:36 PM Re: HMDA file/data stored where? Trees
Truffle Royale Offline

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Thanks, Kathleen. I should have qualified my previous post with the fact that I'm not a CRA reporter so I just have my LAR in a binder. If someone were to ask, I'd print a copy from FFIEC by going to Data Listing Report and selecting the Public Release version.

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#1791890 - 03/06/13 04:29 PM Re: HMDA file/data stored where? Trees
SMQ, CRCM Offline
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Joined: Apr 2001
Posts: 4,828
Between the lines
I think Kathleen is speaking to the CRA (Community Reinvestment Act) rules rather than CRA reporter.

Data available upon request, etc., public file. We have the lobby signs as required, but the data is kept on our network (pdf) and printed upon request. Why print out lots of copies for branches where it will never be requested, but you can bet dollars to donuts that if someone does ask, they will hand them an out of date file.

We have had 1 request in 20 years. A few years ago when these public groups were requesting from everyone and they wanted it in excel format. When we responded that we would send them a paper file (as is allowed), they canceled the request.
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#1791911 - 03/06/13 04:54 PM Re: HMDA file/data stored where? Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Truffles bank does not report for Community Reinvestment Act.

Re public files, HMDA LARs, etc. I am a big believer in electronic files, to save work and paper. It takes time to keep those binders up to date.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1795293 - 03/15/13 04:14 PM Re: HMDA file/data stored where? Trees
RATA_Guru Offline
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Joined: Mar 2013
Posts: 12
Florida
It is best to keep the data electronically for all years and print on demand when needed. If you can filter the data, you can provide subsets of the data instead of the entire data file as well.

Most of our clients prefer to distribute as PDF documents to minimize paper and cost.

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