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HMDA Reason for Denial
05/17/2004
I work at a state bank, regulated by the FDIC. Do we have to report reasons for denial or is it still an option for 2004?
HMDA Reportable Assisted Living Residence
05/17/2004
Is a loan made for an assisted-living residence HMDA-reportable? Also, if more than 4 individuals live in the home, would it be multifamily?
FCRA & Telephone Applications
05/17/2004
Do we have sufficient authorization to pull a credit report when we take a telephone application?
Record Retention for Denied Loans
05/17/2004
Is the retention period for denied loans two years?
Who Should Certify HMDA Data
05/17/2004
HMDA requires an officer of a financial institution to certify the accuracy of the data. The regulation is silent on which officer should certify the accuracy. I believe this responsibility should reside with the Compliance Officer, not Internal Audit. Do you know of any announcements, etc., regarding this, or are you aware of what the "norm" is at other financial institutions?