Banker's Compliance Consulting Blog

HMDA Data: Prove It!

Written by David Dickinson | Apr 4, 2022 2:38:43 PM

Be sure to JOIN US for our webinar, “HMDA Data for Large Filers”.

If you are a “large filer” for HMDA, you know there is a lot of data you’re required to collect and report on your HMDA-LAR. That data also needs to be as accurate as possible so you don’t get into hot water with your examiners. You need to strive for perfection and be able to prove it.

David explains more in the video.

 

Transcript:

I need you to pick up your pen first, and I want you to write this down. Prove it. Okay. Nowhere in HMDA Reg. C will you find this thing that says prove it, but there's an underlying understanding that says, "If you can't prove it, it's wrong." When it comes to HMDA, it's very much garbage-in, garbage-out type of mentality. They want exact and perfection. We're going to talk about the audit standards at the end. Most regulations, what I like to say is, you are not trying to eliminate errors. You're trying to mitigate errors. When it comes to HMDA, I really can't make that statement. It is about perfection, and you have a very low tolerance. It's sad to me, but they are very, very tough on the margins that you get. Again, we'll come back to that a little bit later.

All right. So prove it. Make sure you always have the documentation. You might be right, but if you can't prove that you're right, you're wrong when it comes to HMDA.

Published
2022/04/04