TOPIC: Procedures

HMDA Process & Owners

VP at a bank ($595MUSA)
Hi there, I was looking for some feedback on your HMDA process. We are struggling with our HMDA process. Currently our Loan Ops completes our HMDA form, Compliance then completes a the same exact form (because they "do not trust" the Loan Ops folks), and then a second person in Compliance reviews the form that was completed was correct. I was curious as to:

  1. Who owns the HMDA data gather process?
  2. Who reviews the HMDA data?
  3. Which person approves the data to go on the LAR?
  4. Are the HMDA data gathering forms scanned? If so, is it just the form or are the documents used as evidence scanned.. or both?
If it's easier to e-mail about this my e-mail is: