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
Regulatory Updates – Third Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q3. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here.As always, TCA is here to help with A Better Way to answer all your […]
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 2 of a 3 Part Series In our last article, TCA recapped items necessary for origination and proper disclosure of ARM Loans. In this second article, we will review the requirements for complying with underwriting requirements unique to Adjustable-Rate Mortgages. Underwriting ARM Loans While banks are required to comply with the Ability-to-Repay standards in […]
Regulatory Updates – Second Quarter 2023
Below is a link to the Regulatory Updates as of the end of Q2. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here. As always, TCA is here to help with A Better Way to answer all […]
“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
Part 1 of a 3 Part Series For many years, we have experienced a low interest rate environment and originated predominantly fixed rate mortgages. Well times are changing – with the increase in interest rates, the popularity of Adjustable-Rate Mortgages is gaining momentum. We might be a little “rusty” in the process of originating and […]
FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion
The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating […]
FDIC Name Change – Updated, Again
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance […]
