TOPICS

Friday, April 13, 2018

HMDA Data Resubmissions

QUESTION
We know that you do HMDA and Fair Lending reviews. Recently, we realized that we will need to refile our HMDA data. So, our question is, do we have to disclose why we are refiling? Also, can we just refile part of the HMDA data that needs update rather than the entire HMDA data file?

ANSWER
We have conducted many HMDA, CRA, and Fair Lending reviews, so please be assured that your questions are entirely appropriate. If you need assistance with this matter or any other HMDA-related matter, please feel free to contact us HERE.

Institutions are expected to submit Loan Application Registers that contain valid and accurate HMDA data. However, if an institution discovers errors or omissions in connection with submitted HMDA data, the institution may resubmit the HMDA data.

If a data submission involves revisions or deletions of previously submitted data, it must state the total of all line entries contained in that submission, including both those representing revisions or deletions of previously submitted entries, and those that are being resubmitted unchanged or are being submitted for the first time.

When an institution resubmits HMDA data it must resubmit all the HMDA data. Partial resubmissions of data are not permitted.

A resubmission of data must indicate the reason for the resubmission.

Jonathan Foxx
Managing Director
Lenders Compliance Group