And in light of the fact that under the new proposed HMDA rules and certain FI's having to submit their data on a quarterly basis, are you saying that if the MSA's change after any one quarter, those FI's would have to update and resubmit their data?
Well, that is a good subject for your comment letter.
As far as the 30-day rule, the expectation is that the data will be accurate as of that date. Banks have gone to some sort of annual scrub of the data before submission of their own accord to ensure that the data is absolutely accurate prior to submission. However, that does not negate the regulatory requirement. If an event happens that makes the current LAR data inaccurate, yes you should correct.
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