Just How Clean Is Your HMDA Data?

Written by: Bill Dolan, CMB, AMP

Both banks and credit unions are facing greater intensity and scrutiny when having their HMDA data tested during their fair lending and CRA examinations. It is the data you are providing in your Loan Application Register (LAR) that the regulators focus in on when analyzing the data you produce from your institution’s lending records.

The most common mistakes identified during examinations are the following:

• Human errors, especially keystroking mistakes.

• Misinterpretation of actual reporting requirements.

• Geocoding errors.

• Reporting the renewal of a small-business loan as an origination.

Here at SCA, we realize just how high the stakes are when it comes to preventing data integrity problems. To prevent persistent data integrity issues, management within banks or credit unions alike, must ensure proper attention to these data problems and take immediate corrective action prior to your LAR submission to the CFPB.

At SCA, whether our HMDA analytics team is analyzing your data through a full LAR review ort taking a percentage of your LAR for review, SCA will improve the accuracy of your HMDA data by providing the following:

• Test the integrity of your data to avoid risk exposure.

• Train your staff in-depth in what constitutes a reportable HMDA loan.

• Track the flow of your data.

• Provide best practices and recommendations in conducting a Fair Lending risk and LAR assessment at least annually.

See just what SCA can do for you by contacting Bill Dolan, Director, at: WDolan@scapartnering.com or at: (617) 694-2617. While you are at it, visit our Solutions page to learn more of the consulting and fulfillment services that we offer our clients. Don’t wait for the regulators to identify your issues prior to your next examination. Contact us Today!!!