Posted By: DebbieC
CRA and HMDA - double reporting - 10/06/05 04:21 PM
I've been told by our CRA Officer that it is appropriate to post refinances on both the HMDA and the CRA LARs(double reporting)due to the 2004 changes in the way we look at refinances. Is this true?
If so, were can I find information in the regulations that support this. Thanks
Posted By: Dan Persfull
Re: CRA and HMDA - double reporting - 10/06/05 04:58 PM
Do a search in the CRA and Lending Compliance forums using "double reporting" and you will find several threads discussing the issue.
Here's one to get you started.
Posted By: HRH Dawnie
Re: CRA and HMDA - double reporting - 10/06/05 06:10 PM
Just for clarification....there is no such thing as a CRA LAR. For CRA you submit an LR and for HMDA you submit an LAR.
You can record all the loans on your CRA LR that you wish to, but for the actual submission, only type 1 and 2 loans will be submitted, which means you're wasting time entering type 3 loans (secured with residential collateral that is not multifamily). If your CRA officer wants these tracked (I track everything) go for it. If you are doing a great deal of hand entry, and don't need the type 3 deals during exam, don't bother.