We are new to large bank reporting requirements. Who prepares the annual reports at your institutions? Which department is responsible for this information?

At our bank, it's me, the Compliance Officer. I don't have a department. Or staff. Our CRA Officer is more a Business Development/Relationship Manager position. He helps with some of the research on the loans to be reported, but he is out more than he is in.

I (well I guess my staff) have that responsability here at my institution. I review the data, ensure data integrity and review the majority of the lending portfolio for CD potential.

I think you're going to find that the answer varies greatly from institution to institution based on size, reporting requirements and complexity of the bank's systems. As with much of CRA, there isn't a quick easy answer

I as the CRA officer and Compliance officer am responsible for CRA reporting for my institution. However, I have provided extensive training to the loan staff at each of the branches. It is their responsibility to report accurate data and to flag loans that are refinancings in the same year or have a different loan address than the CIF address for that customer.

In larger banks what area (Compliance, CRA, business line, etc.) is typically responsible for the CRA and HMDA reporting (including data accuracy). Is CRA and HMDA reporting usually under the same area of responsiblity?

Any information on the structure of the HMDA and CRA data reporting areas would be helpful including any pros and cons.

$4 billion in size with 31 assessment areas and 11 MSAs here, hmda and cra reporting handled by Compliance department. It helps though that we have well trained front end loan staff compiling the data and using software to check for validity errors.

$2 billion with 10 AA's and 2 MSA's. We have HMDA in the compliance department, but I also get my fingers in the pie because the ultimate value of the data is reflected in my CRA exam. I am responsible for all CRA submission, including data integrity.

$260 million bank with one AA and one MSA. I am the CRA Officer, work in Loan Administration and prepare the CRA LR. Our HMDA LAR is prepared by someone in Loan Operations and I run also an edit check on the LAR. Our Compliance Auditor also audits both the HMDA LAR and CRA and we also have the Loan Operations Manager audit the entire HMDA LAR.

That makes 4 people who review the HMDA LAR and only 2 that review the CRA LR. I guess I feel a little unimportant today.

$11 billion; business areas responsible for data integrity.
I (CO) file the Federal CRA LR. The Residential/Consumer Loan area files the bankwide HMDA LAR.

You should have more people reviewing the HMDA LAR. Screw that one up and you go to jail or pay money out of your pocket. Screw up CRA...you refile with a slap on your little CRA hand for mussing up your data integrity.

I have 2 reviewing the LR and hummmm five to six with their hands on the LAR. We push the LR button in my office and the mortgage dept pushes the LAR button (although we are the back up). We're a 2 billion bank Heck you're in much better shape than me Can I borrow a body you're using on the LR?