Welcome back to ADI's quarterly Q&A series, HMDA Huddle. With the third quarter of 2022 ending and the end of the year approaching, it's critical to keep a strong focus on HMDA compliance. Lenders should continue to sharpen procedures and monitor the accuracy of all year-to-date LAR recordings. If you let this process slip earlier [...]
Under the Community Reinvestment Act (CRA), examiners will assess the community credit and development needs in a bank’s assessment area. A community credit needs assessment – which may also be referred to as a community needs assessment – is a component of the analysis of performance context in a CRA examination. It is intended to [...]
Get It Right: It’s a mantra for HMDA reporting, and it’s equally critical in CRA small business reporting for regulatory compliance. Three of the four critical fields to CRA reporting routinely cause lenders problems: Loan Amount, Loan Location and Gross Annual Revenues of $1 Million or Less. The right answer depends on such specifics as [...]
Welcome back to ADI's quarterly HMDA Q&A series, HMDA Huddle. As the end of the second quarter of 2022 approaches, HMDA compliance should remain a consistent focus. Many lenders loosen procedures and fall back into pitfalls of inaccuracy after their previous year's LAR is filed. Don't let that happen to your institution, as it will [...]
Welcome to ADI's first issue of our quarterly HMDA Q&A series, HMDA Huddle. With another HMDA filing deadline behind us, lenders who successfully submitted their 2021 LAR can breathe a sigh of relief, and ADI is already looking ahead to 2022 reporting. ADI assists a wide variety of lender clients with HMDA LAR audit and [...]
Guidance on the Home Mortgage Disclosure Act (HMDA) provides instructions for how lenders should report each Loan Application Register (LAR) field. For most fields, the instruction is specific and leaves no room for differing interpretation or options for lenders to choose when reporting their LAR. For a handful of LAR fields, however, there is some [...]
Download This Article In two past Knowledge Center posts (Post 1 and Post 2), we discussed eight common errors that lenders encounter when satisfying reporting requirements under the Home Mortgage Disclosure Act (HMDA). The errors that we reviewed included: Failing to capture all HMDA-reportable transactions Reporting the incorrect loan amount Assigning the wrong geographies via [...]
Download This Article Withdrawn applications reflect an increasing proportion of non-approved first-lien mortgage applications as denials have become relatively less numerous. A decade ago, based on 2009 HMDA data, denials comprised just over one-half (53 percent) of non-approved first-lien applications. Denials fell to less than one-third (31 percent) of non-approvals a decade later. Over the [...]
On January 1, 2021, Congress passed the National Defense Authorization Act (NDAA), addressing a variety of defense and national security matters, including the most substantial and sweeping legislative reforms to US anti-money laundering (AML) and counter-terrorism financing (CFT) laws since the USA Patriot Act of 2001. The NDAA introduces these AML/CFT amendments and enhancements in [...]
Download This Article With the transition between presidential administrations, new regulations, and the ongoing effects from the pandemic and corresponding economic crisis, lenders are facing a dynamic environment in 2021 with respect to managing compliance risk under Fair Lending laws and the Community Reinvestment Act (CRA). There is another factor, however, receiving less attention but [...]
