Hi

The FDIC was in in May 2013 and found some significant errors in our 2011 and 2012 HMDA reports. We are required to refile both years after doing a complete scrub.

I vaguely remember being told by an examiner of a November date for our 2011 LARS....so my question is this:

Is there a (specific) date for any kind of HMDA resubmissions? (I can't find anything specific online on the FFIEC website or the Getting it Right book)

If you are resubmitting a current year, there is a date that determines whether your reports will reflect the original submission or the new submission. I can't remember the date. (It's a mute point, as resubmit when you have to.)

Since you are resubmitting 2011 and 2012, it won't matter, you will not received updated reports. However, it is never too late if an examiner tells you to resubmit. I once resubmitted on Dec. 8!!! Don't ask.

And you are past the date where resubmissions are not accepted, so you just go ahead.

The situation - our regulatory agency has previously identified HMDA issues and we had to resubmit 2010 and 2011 LAR. I don't think we will exceed the exceed the 5% column threshold but there is a chance that 10% of the total entries may have one or more key field entries. One of the mitigating issues for potential enforcement action is whether we self-identified and took corrective action such as refiling.

While a formal audit or HMDA scrub hasn't been conducted the chance of a 10% error rate is a valid concern. Would you consider "self-identifying" and refiling - our examiners are scheduled to be here in a few months - or rolling the dice and hope the error rate is less than 10% in the key fields. The LAR in question is both the 2011 LAR which was already resubmitted once but likely still contains errors as well as the 2012 LAR.

I'm of the mindset that it's always in the institution's best interest to self-identify and correct. So if it was me, I'd push for a scrub now (before the exam).

Definitely scrub before exam. It is not the regulators job to find your problems.

I haven't worked for a HMDA bank for going on 8 years now. We will be subject to HMDA next year to report in 2015. What is the acceptable error rate for HMDA? Thank you.

Who is your regulator? Here is a discussion that covers CFPB and FRB: http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1860220

OCC. I believe each line has 26 pieces of data. If you have 1 error out of 26, does that count as 3.8%? Or if you are reporting 500 applications on your LAR and 25 of the applications have one or more errors, is that a 5% error rate?

We are FDIC and we've gone by 5% in any key data field, 10% overall.

Refer to the OCC HMDA booklet and search on resub


HMDA data resubmission should be considered if any of the following
descriptions applies:
Any one key field is incorrectly reported for at least 5 percent of the
loan application records sampled;
At least 10 percent of the banks loan application records sampled
have an error in at least one of the key fields; or
Errors in submitted data prevent an accurate evaluation of the
banks CRA performance.

If a bank consistently has errors, a lower error rate can be used.

The FDIC has a sampling matrix in their HMDA Exam procedures that tells you the number of allowable incorrect data fields before they will require resubmission. It's on page 22 of their exam procedures, which can be found here:

http://www.fdic.gov/regulations/compliance/manual/pdf/V-9.1.pdf

Thanks everyone. I greatly appreciate it.

This would scare me...a lot!
I wouldn't have resubmitted this until I was pretty dang sure it was clean on all fronts, not just the field the examiners caught.
So yes, if I were you, I'd be scrubbing like crazy and resubmit this again BEFORE the examiners got there.