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 – 2021
It’s challenging for every Compliance professional to stay on top of the small and big changes to existing and new regulatory requirements. As you partner in compliance, we are introducing a new feature to our Regulatory Compliance Manager (RCM) Service – Quarterly Regulatory Updates.This is A Better Way for you to keep track of regulatory […]
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. […]
When the Tide is Against You
Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]
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 […]
The Great Debate — Is This a Finance Charge?
If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly […]
