A Guide to HMDA Reporting - ffiec
A Guide to HMDA Reporting - ffiec
A Guide to HMDA Reporting - ffiec
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Introduction An institution must transmit its LAR <strong>to</strong><br />
the processing agency indicated by<br />
its supervisory agency, ordinarily in<br />
electronic form, and preferably by<br />
Internet e-mail as an encrypted file<br />
(hmdaencr.enc) attachment. Instructions<br />
concerning transmittal can be<br />
found in Submitting the LAR. Every<br />
reporting institution must also disclose<br />
its LAR <strong>to</strong> the public after deleting information<br />
that might compromise consumer<br />
privacy. See Disclosing the Data.<br />
2<br />
The FFIEC, on behalf of the agencies,<br />
creates a series of tables from each<br />
institution’s data. Every institution must<br />
make its tables available <strong>to</strong> the public.<br />
In addition, the FFIEC will prepare and<br />
release tables that aggregate all reporting<br />
institutions’ data by metropolitan statistical<br />
area or metropolitan division.<br />
Those disclosures are discussed in more<br />
detail in Disclosing the Data.<br />
Management's<br />
Responsibilities<br />
If your institution is required <strong>to</strong> comply<br />
with <strong>HMDA</strong>, management must ensure<br />
that:<br />
¢ Procedures are in place for collecting<br />
and maintaining accurate data<br />
regarding each loan application,<br />
loan origination, and loan purchase—<br />
for home purchase loans, home<br />
improvement loans, and refinancings.<br />
¢ The individuals assigned responsibility<br />
for preparing and maintaining<br />
the data understand the regula<strong>to</strong>ry<br />
requirements and are given the<br />
resources and <strong>to</strong>ols needed <strong>to</strong> produce<br />
complete and accurate data.<br />
¢ Appropriate record entries are made<br />
on the LAR within thirty calendar<br />
days after the end of the calendar<br />
quarter in which final action occurs<br />
(such as origination or purchase of a<br />
loan, or denial or withdrawal of an<br />
application). For loans sold, the type<br />
of purchaser may be added later.<br />
¢ An officer of the institution moni<strong>to</strong>rs<br />
the collection of the loan/application<br />
data during the course of the year<br />
for compliance with the reporting<br />
instructions, reviews the data, and<br />
certifies the accuracy of the data<br />
submitted <strong>to</strong> the institution’s processing<br />
agency at year-end.<br />
¢ The loan/application data are submitted<br />
annually on time (by March 1<br />
following the calendar year of the<br />
data), and the institution responds<br />
promptly <strong>to</strong> any questions that may<br />
arise during processing of the data<br />
submitted.<br />
Administrative sanctions. Given the<br />
importance of accurate and timely submission<br />
of <strong>HMDA</strong> data, a violation of the<br />
reporting requirements may subject the<br />
reporting institution <strong>to</strong> administrative<br />
sanctions, including the imposition of<br />
civil money penalties, where applicable.