Getting It Right!

By Bill Dolan, CMB

As you frantically complete your last-minute changes and tweak your 2019 HMDA data for submission to the CFPB by March 1, 2020, you’ll finally get to breathe a major sigh of relief. Be advised however, you may still not be out of the woods, even then.

Rumor has it that the examiners are not only awaiting your 2019 LAR, but recent calls and engagements that SCA are performing for several institutions, have advised us that they are being notified that their next regularly scheduled on-site compliance exam will include a look-back of the 2018 LAR as well. Regulators want to be assured that you in fact, reviewed and revised (cleaned any erroneous data points) your previously submitted LAR for 2018. Though you may have been given a reprieve from monetary penalties last year, you are not exempt from correcting the data submitted.

The HMDA data needless to say, is being utilized by the regulators to perform their own analytics to monitor geographic targets, provide an identification mechanism to determine possible predatory lending practices and to create reporting statistics on the mortgage market.

If you are looking for SCA to provide a solution to help address/resolve any potential errors you have existing on the 2018 LAR and require your immediate attention (do you know your next exam date?) or, should you require assistance reviewing your current 2019 LAR prior to this year’s submission, please reach out to SCA and Bill Dolan at (781) 356-2772 or by email at: wdolan@scapartnering.com