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#1950731 - 08/08/14 02:23 PM FFIEC Geocod activity year update
blondie8012 Offline
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Joined: Dec 2009
Posts: 91
Hi Bolers,

TGIF! Does anyone know if our hmda-reportable loans, since the beginning of this year, need to be scrubbed for MSA info accuracy; since we just got the FFIEC alert that the activity year has been updated (2014)?

I have tried to find and cannot seem to come up with any answer.

Thank you for any assistance.

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#1950743 - 08/08/14 02:38 PM Re: FFIEC Geocod activity year update blondie8012
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Sec. 1003.4 Compilation of loan data.

(a) Data format and itemization.

All reportable transactions shall be recorded, within thirty calendar days after the end of the calendar quarter in which final action is taken (such as origination or purchase of a loan, or denial or withdrawal of an application), on a register in the format prescribed in Appendix A of this part.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1950759 - 08/08/14 03:00 PM Re: FFIEC Geocod activity year update blondie8012
Kathleen O. Blanchard Offline

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Yes, you will have to update the MSAs. If you do not have software that does that for you, you could import a dat file into the FFIEC software and run a validity error report. That will tell you what MSA numbers are incorrect.
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#1950783 - 08/08/14 03:23 PM Re: FFIEC Geocod activity year update blondie8012
MassCompliance4 Offline
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MassCompliance4
Joined: Sep 2009
Posts: 24
MA
I am confused by Randy's and Kathleen's answers as they seem to be contradictory?

I took Randy's response to be that, no, you need not go back and change your early HMDA data as this data was supposed to be "finalized" within 30 days after quarter close. But Miss Kathleen's response clearly says we need to rescrub.

This issue has also been raised at my bank in regards to both our HMDA data and CRA data and the need to rescrub when the FFIEC data changes. 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? Whether we are required to actually submit the data after each quarter, the fact is that our data is supposed to be in the "reportable format" within that 30-day window after quarter close...so to me....no changes unless an actual error was made by the FI. Can you clarify? Thanks to both Randy and Kathleen, as always!!

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#1950784 - 08/08/14 03:23 PM Re: FFIEC Geocod activity year update blondie8012
blondie8012 Offline
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Joined: Dec 2009
Posts: 91
Thank you RL and Kathleen, I appreciate your assistance.

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#1950785 - 08/08/14 03:26 PM Re: FFIEC Geocod activity year update blondie8012
Kathleen O. Blanchard Offline

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Posts: 21,293
If you do not update (and do not have software that will update for you) you will have incorrect MSAs in your data. That means if you submit an annual report, it will have validity errors and fail the batch edit test.

We cannot predict how the periodic changes will be handled if the proposed quarterly reporting for large filers is finalized.

That would be a good question to ask in a comment letter.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1950824 - 08/08/14 04:01 PM Re: FFIEC Geocod activity year update blondie8012
rlcarey Online
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Galveston, TX
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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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1950862 - 08/08/14 04:20 PM Re: FFIEC Geocod activity year update blondie8012
MassCompliance4 Offline
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MassCompliance4
Joined: Sep 2009
Posts: 24
MA
Thanks to you both for clarifying for me!! *on my way back to Residential Lending* *whistling as I go.....

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