Rooting out your HMDA compliance gaps and preparing you for a successful exam.
We perform exhaustive reviews to confirm that your HMDA data are complete and accurate and conform to examiners’ expectations.
Gathering the accurate and complete HMDA data regulators require can haunt banks come exam time.
You worry about human and systematic errors, gaps in your lending areas, including your commercial lending practices, and whether you've interpreted HMDA requirements correctly.
In many ways, it takes a village to ensure that you're meeting regulators' expectations and that staff across your business lines collect, record, and present all HMDA-required data consistently, effectively, and accurately.
TCA can be part of your village. Our team members, all former bankers, know where banks get tripped up by HMDA.
As such, banks have relied on us for HMDA reviews for decades. We reduce the stress associated with anticipating and preparing for HMDA exams and we give you the confidence that you’ll be ready when an examiner steps through the door.
Through our discovery, we shed light on whether your policies or approaches are missing key regulatory requirements. In addition, our consultants study the latest regulatory changes and understand what they mean to your bank.
Some of the services you can expect:
- A review of your LAR to assess whether your data collection and reporting are accurate and adhere to HMDA requirements
- A deeper dive through custom samples to identify HMDA trouble spots
- Advice on HMDA data validations to ensure you have trust in the integrity of your data
- An analysis of procedures and workflow
We also look for common mistakes we've encountered:
- Inaccurate loan amounts.
- Geocoding and Census Tract changes that aren't reflected in the files.
- Lending transaction bank fees that are missing from the file.
- Missing documentation related to income and credit decision dates.
TCA shows you A Better Way to overcome your HMDA compliance struggles.
Key deliverables include:
- Outlining how to develop an ongoing monitoring strategy to avoid compliance gaps
- Updating your team on the newest HMDA reporting requirements
- Identifying staff training deficiencies
- Advising on HMDA policies and procedures and measures to enhance data collection
Additional Compliance Topics
Do you Remember? HMDA – Reporting Open-End Lines of Credit
It’s time for a trip into the Way-Back Machine, all the way back to April 16, 2020, when the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C. This amendment permanently raised the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years. The […]
HMDA and HPML Thresholds Bumped Up for 2022
The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price Index for Urban Wage […]
CFPB Releases HMDA Public Data Tables
The CFPB has released the public disclosures for HMDA data submitted for calendar year 2020. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As a reminder, the tables are no longer required to be made a part of your CRA Public File. […]
HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption?
Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the […]
Considerations for Managing an Offsite Review
They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the […]
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