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#163827 - 02/25/04 03:52 PM CRA & HMDA Data Submissions
Some Days You Just Can't Win Offline
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Some Days You Just Can't Win
Joined: Feb 2002
Posts: 461
Mississippi River Valley
Our organization is in a multi-bank environment - 5 separate charters (each with multiple branches). We are moving to a new loan software vendor and are discussing a number of different issues, but the one that seemed to have the most impact on the implementation is the interface for HMDA reporting.

Currently, each charter creates a separate HMDA Loan Application Report for their bank(s) and submit them separately.

Is it acceptable for us at the Bank Holding Company level to submit a single HMDA LAR for all of the banks in the BHC combined?

Any thoughts or comments are appreciated.
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#163828 - 02/25/04 05:07 PM Re: CRA & HMDA Data Submissions
hmdagal Offline
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hmdagal
Joined: Dec 2002
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No. For many years we had almost 30 charters, and if I remember correctly, 19 of them were required to report HMDA data. They did not all have the same regulatory agency. I submitted a separate LAR for each (and that was in the days before being able to email the submissions). One of the savings that resulted when we collapsed charters was in the HMDA area. We still have 3 charters, but that's a breeze in comparison to what it had been.

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#163829 - 02/25/04 08:31 PM Re: CRA & HMDA Data Submissions
Some Days You Just Can't Win Offline
Gold Star
Some Days You Just Can't Win
Joined: Feb 2002
Posts: 461
Mississippi River Valley
FYI

I found the answers to my question regarding the HMDA reporting for multiple banks on the FFIEC web site. The answer is:

We can include HMDA LAR information for multiple banks in a single file, provided we include the unique Respondent ID with each record and provide a transmittal record summarizing each Respondent ID in the file.

Just thought you'd like to know. Thanks.
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#163830 - 02/25/04 09:18 PM Re: CRA & HMDA Data Submissions
Lestie G Offline

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Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
Quote:

No. For many years we had almost 30 charters, and if I remember correctly, 19 of them were required to report HMDA data. They did not all have the same regulatory agency. I submitted a separate LAR for each (and that was in the days before being able to email the submissions). One of the savings that resulted when we collapsed charters was in the HMDA area. We still have 3 charters, but that's a breeze in comparison to what it had been.



Oooooohhh, hmdagal - that made me cringe! Thanks goodness for collapsed charters! I thought I was being punished when I had three different LAR's to submit!
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#163831 - 02/25/04 10:38 PM Re: CRA & HMDA Data Submissions
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,842
Quote:

Quote:

No. For many years we had almost 30 charters, and if I remember correctly, 19 of them were required to report HMDA data. They did not all have the same regulatory agency. I submitted a separate LAR for each (and that was in the days before being able to email the submissions). One of the savings that resulted when we collapsed charters was in the HMDA area. We still have 3 charters, but that's a breeze in comparison to what it had been.



Oooooohhh, hmdagal - that made me cringe! Thanks goodness for collapsed charters! I thought I was being punished when I had three different LAR's to submit!



Yeah. It used to be pretty ugly around here at submission time. Each of the unit banks needed hard copies of their reports as well as a diskette with the information. Of course, I had to keep copies of everything I sent out....

Even though we submit many more records now, submission time is so much easier than it used to be.

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