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
