We have always used the FFIEC Software to collect and submit our HMDA Data. We're considering using our core software (Jack Henry CIF 20/20). Does anyone else have the same core software and is using it to collect and submit the HMDA Data?

Any advice would be greatly appreciated.

I don't think you can submit using anything but the FFIEC software.

You can, however, collect your HMDA data in whatever loan software you use and export it into the FFIEC software to submit it. We use FICS Loan Producer to create the HMDA file and then export it.

Some of the software systems have the FFIEC software incorporated in them, so you don't have to do a data export. I'm not familiar with Jack Henry.

Actually, you can submit without using the FFIEC software. We have been using QuestSoft's HMDA Relief for years, and have submitted our report using this software.

Of course, resident within the software is all the compliant features and processes.

There are a few issues here.

1. You can use any software you like to submit but data MUST be validity error free and in the proper FFIEC format. In addition, the submission by email MUST be encrypted using only the FFIEC supplied encryption prgram (which is separate from the data entry software).

As far as everyone using FFIEC software, actually over 3/4ths of the records submitted to the FFIEC accounting for about 1/2 of all financial institutions are submitted using either Pci's CRAWiz or QuestSoft's HMDA RELIEF. (In the interest of full disclosure, I am president of QuestSoft and according to the 2007 FFIEC HMDA LAR, we had 1,554 customers successfully submit 3.78 million records). The reasons for using FFIEC software is that it is free and the government's official software. For the 4,000 institutions that submit 100 records or less, it is usually a good choice. But it also is very mannual. The reasons for using another product are that they usually automate a lot of the process (for example, our customers say they usually save about 90% of the time to scrub, geocode and submit the data). Another reason you might select a third party is customer support which tends to be live voices (vs email) and very responsive.

2. re Jack Henry. Jack Henry is one of the major core processing systems. Every system that processes mortgages stores HMDA information because it is on the loan application. However, that data is not scrubbed for accuracy, geocoding, or errors (proper combo of race/sex, etc) and that is where people get into trouble and the FFIEC/FRB gets upset. You cannot take that file export and just email it to hmdasub@frb.gov without putting it through HMDA specific software first. It is guaranteed to come back and you will have probably experience the wrath of the FRB if you attempt a second shot. This is why you usually see post on BOL refering to HMDA in a different word than Heaven and being very specific in emphasing accuracy.

All loan software products have some way to export the data out (some might charge for that) to the HMDA.DAT format. If you want to go the FFIEC software route, I would check with your Jack Henry customer support to find out how to perform that export. It should be a pretty common question during this time of year.

I'm very proud of my HMDA submissions and I don't use any purchased software programs. I import the LAR from Loan Processor into Excel and do a pivot table to scrub. Andy Z wrote an excellent article in the ABA magazine a while back oulining the pivot table process step by step.

Pivoting does all the same types of comparisons Leonard talks about above. I make any corrections necessary in Loan Processor and then import the LAR into the FFIEC software to submit it.

Just wanted you to know there are ways to do this in case your institution just doesn't have it in the budget to purchase new software this year.

Truffle,

I hope I didn't offend. Yes, you don't have to have a third party software package and many people are able to get through just fine.

My only point was the FFIEC software is fine for many, impracticable for some and there are proven, perfectable acceptable alternatives and reasons you might want to use them. You have to give me a little here too. When we geocode 95% of records at 4,000 records per minute and you only need to look up 5% manually, HMDA gets done a little faster than 2-3 minutes per record at the FFIEC geocoding web site that most people tell me it takes. And most banks fund in a single state or two so the geocoding cost is under $300 for most. For people with lower volumes or who wish to double check every record on the FFIEC site anyway, your way is very practical.

Plus, I have no idea how many records are being discussed here so I have no recommendation one way or the other.

Congratulations on your efficient submission and again, I hope you weren't offended by my post.

Absolutely no offense taken, Leonard, ...and none meant either.

My own submission for this year will be under 2000 lines and I'm able to manage it with the pivot tables my examiner taught me how to use. I cannot imagine doing huge LARs without the help of products like your's.

My bank works with community banks who just don't have the budgets they did even a year or two ago. Most of them have small LARs too. For them, pivoting is a free, viable option that eliminates pouring over the submission line by line, hoping to catch the mistakes.

I think both of our methods offer solutions to those of us who make our living through the advent of Reg C.