Compliance Blog

Written by Steve Van Beek

I enjoy getting my hands on any type of resource that can be helpful to credit unions.  I'm passing three on today that I hope are useful to you.

CRA/HMDA Reporter.  Obviously, the CRA part isn't applicable to credit unions - but, the HMDA parts are very detailed and highlight common mistakes from HMDA filers.  Here is a sample from the Reporter:

"What Triggers a Recreated HMDA Disclosure Report?

Many institutions resubmit their HMDA data after the initial March 1 deadline for a reporting year. A resubmission of data can generate a Recreated Disclosure Report (a “recreate”) depending on the date the data is resubmitted. If an institution resubmits before the last Wednesday of April for the current reporting year, a recreate will not be generated.

The resubmitted data will be reflected in the public disclosure reports released the following September on the Federal Financial Institutions Examination Council’s (FFIEC) HMDA website (at www.ffiec.gov/hmdaadwebreport/DisWelcome.aspx). Any resubmission for that year that takes place after the April cutoff date will not be reflected in the public disclosure report, but a recreate will be e-mailed to the institution.

A recreate will be e-mailed to an institution once it has been successfully marked complete and after the public data have been posted to the FFIEC HMDA website. To be marked complete and receive a recreate, an institution must indicate the reason for resubmission (such as a bank exam or internal audit) on the Confirmation Sheet.  If a resubmission was due to a bank exam, the institution must specify what type(s) of error was discovered that warranted a resubmission.

Once the above information is verified, an institution will be marked complete and its recreated disclosure report will generate overnight. It will be e-mailed the next day or following the September public release to the contact person listed on the Transmittal Sheet."

Additionally, this might be the most helpful as well:

"Signing up for E-mail Alerts

Q:  How can I be notified when the HMDA Aggregate and Disclosure Reports have been released to the public?

A:  HMDA Alerts are distributed when updates or revisions about HMDA data are posted to the FFIEC HMDA website; this includes the public release of the HMDA Aggregate and Disclosure Reports.

To sign up, go to www.ffiec.gov/hmda and click on the “E-mail Alert Sign-Up” icon. You will be asked to enter and confirm your e-mail address. (Subscribers can also update or remove e-mail addresses using this same link and selecting “Subscriber Preferences.”)"

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Current Issues in Credit Unions.  The latest Current Issues in Credit Unions podcast (#76) is now available.

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KaufCan Fall Update.  A very good article on Bankruptcy Changes is also worth reviewing.