A Guide to HMDA Reporting - ffiec

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