Auditing for Compliance Part II: HMDA
The Home Mortgage Disclosure Act (HMDA) requires covered financial institutions to compile and disclose data about home purchase loans, home improvement loans and refinancings that they originate or purchase, or for which they receive applications.
HMDA errors can result in civil money penalties, negative publicity, increased regulatory scrutiny and attention from the Department of Justice.
- Understand the rate spreads
- Identify potential HMDA applications from loan and denial files
- Root out the “real story” behind withdrawn applications
- Distinguish between “temporary” and “short term” financing
- Recognize refinancings that were previously not “reportable”
- Spot possible errors from simply looking at the LAR
- Verify data accuracy against source documents, and more
Compliance officers, auditors, HMDA input clerks, loan officers.
Patricia Cashman was formerly a partner in Cashman Compliance Solutions, LLC. She was responsible for consumer compliance reviews, BSA/AML reviews, and compliance and BSA training. Patricia began her banking career in 1969. She has been the senior operations officer for three Dallas-Ft. Worth area community banks, an assistant examiner for the Texas Department of Banking and she managed the compliance/internal audit division of TIB – The Independent BankersBank, one of the largest bankers’ banks in the country. Additionally, Patricia has presented webinars for the ABA, BOL and has taught at TBA and ABA Compliance Schools. She has also been a speaker/trainer for numerous banks and compliance organizations.
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