Posted By: dmcpherron
HMDA Loan not reported - 03/29/22 10:09 PM
We have a loan that was not reported in 2021. We reported our HMDA as required by March 1. However, today a loan was found that should have been included in the LAR. What is the proper procedure from here? Do resubmit, add it to Q1, not report?
Posted By: rlcarey
Re: HMDA Loan not reported - 03/30/22 01:47 AM
How many entries were on your LAR?
Posted By: Inherent_Risk
Re: HMDA Loan not reported - 03/30/22 01:06 PM
Resubmit if you think it's worth it. Don't add it to 2022 data, that would just add another error. Resubmitting is not that difficult these days, but we would probably not resubmit for one application. I would investigate why it was missed, if there are any others, and then determine a way to make sure it doesn't happen going forward.
Posted By: dmcpherron
Re: HMDA Loan not reported - 03/30/22 02:02 PM
We had approximately 2800 entries on the 2021 LAR. I was leaning towards not reporting it, but that doesn't feel right.
Posted By: dmcpherron
Re: HMDA Loan not reported - 03/30/22 02:05 PM
Also it is a one off situation. It was due to human error, not a systemic issue. If we had more than one we would definitely resubmit.
Posted By: rlcarey
Re: HMDA Loan not reported - 03/30/22 02:08 PM
I think you might be able to live with an error ratio of .0357%.
Posted By: dmcpherron
Re: HMDA Loan not reported - 03/30/22 02:16 PM
lol - Yes I can live with that error rate. Just wanted to make sure that I wasn't missing something where a missed loan had to be submitted. Thanks for the advice.