Mortg Corp & HMDA

We are a bank and recently started a Mortgage Corp. Do we need to send two different HMDA reports? And, is it typical that for the bank compliance officer to be responsible for the mortgage corp compliance?

I think we are in the same boat as you are. We are taking the stance that you will be responsible for making sure they are in compliance, but obviously you want an operating agreement to remind them that they are responsible for complying with everything. It will be up to you to make sure they do. On the HMDA issue, we are going through the first full year of their operation and they were logging everything the old way, and they were used to recording and reporting like a mortgage company (to HUD instead of FDIC), not as a subsidiary of the bank. They were unaware of this until we were doing our CRA audit, hence the need for your compliance people to be involved in the mortgage company's activities, much to your delight.

Thanks for your quick response. I'd like to have all the departments sign an agreement.
heehee :rollingeyes

OOPS!
:rolleyes

We had a seperate Mortgage Co. and had to file two HMDA reports........then that company became part of the bank and no longer seperate and then we filed one HMDA report.

Left one item out yesterday-our mort co. does report on their own to FDIC (as they should) with their respondent ID # (not ours) and then we report the info we gather here for the bank under our ID#.

We also have a Mortgage Company and they report their HMDA separate from the Bank.