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
No Longer A HMDA Reporter – Fair Lending Still Applies
On April 16, 2020, The Consumer Financial Protection Bureau issued a final rule raising the loan-volume coverage thresholds in Regulation C for financial institutions reporting data under the Home Mortgage Reporting Act (HMDA). A permanent threshold for collecting closed end mortgage reporting data went from 25 to 100 loans effective July 1, 2020. Also, open-end […]
Three Hot CRA Concerns
Minding the pandemic, election and social issues is a lot to focus on but bankers will have to add the Community Reinvestment Act (CRA) to their full plates. There are three hot CRA topics on which to focus since CRA is still very much on the regulatory agencies’ minds. Despite 2020 upending CRA lending programs, […]
Adverse Action Notice Requirements For Loans and Deposits
When you deny a credit application or a deposit account request, you simply fill out a form and move on to the next customer, right? If only it were that simple! This article will clarify the who, what and why of the different requirements for denying loan applications and deposit requests for consumers and businesses […]
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 […]
National Compliance Officer Day
Today is National Compliance Officer Day, so TCA® wanted to share some recommendations from our compliance team with our fellow compliance professionals on potentially banking clients who may be engaged in activities relating to the cannabis industry. The challenge of providing banking services for industrial hemp and CBD Oil is that there are no current […]
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