All,
We believe we may have found 3 loans that should have been included in our yearly HMDA that we've just found were not. We're still in the learning process of HMDA so I'm unsure exactly what we need to do or have to do. Any suggestions would be much appreciated.

How many loans were on your submitted LAR? If 10,000, i probably wouldn't do anything except train and move on. If 100, i'd resubmit.

Roughly 1,800. These 3 were new commercial loans that were HMDA reportable that originated out of a different software and when done were not marked correctly as HMDA reportable.

That's larger than my LAR, so someone with a LAR close to that size might chime in, but it sounds like your first year of HMDA reporting and the allowable error rate for HMDA isn't high (i want to say 3%). Having said that, those 3 loans represent about 1/6 of 1% of your LAR. I think it's going to depend on your comfort level with what you DID submit; your OCD level, etc. Sorry, that's the best advice i have. Like i said, let someone with a LAR along the size of yours chime in.

A few years ago, we resubmitted because we missed 4 loans and our total LAR was about 1300. We were examined on that year's HMDA in 2014 and the FDIC didn't have any issues with us resubmitting. They just asked for an explanation.

I would make sure there aren't any other similar loans that were missed, then make your decision.

Find a rug and a broom. Sweep loans under rug.

For 3 out of 1,800, I would not resubmit.

We purchased a bank on 4/1/15. We have already noted that a resubmission will be needed just by quickly looking over the LAR... how late can we resubmit... because it looks like I am going to have to do a full scrub (and I really don't have time!!)