Bank recently criticized by examiners for not having a process whereby it retained info on underwriting and pricing exceptions which meant no reporting to BOD or Sr Mgt as to frequency or type of exceptions. Pulling together a spreadsheet now to capture key info such as DTI, LTV, loan level info, compensating override factor(s), exception type, etc. Have reviewed other such spreadsheets in past and wondering if its preferable to have a column to indicate whether loan is HMDA reportable or not and to record race, gender and ethnicity on the spreadsheet itself. Doing so would appear to make the review and analysis, as well as identification of any specific disparities, much easier by having GMI info readily available on the exception reporting spreadsheet. Any thoughts? I'm also considering adding a second spreadsheet of exception requests which were not granted and the reason why they were not granted such as the absence of any compensating factors. Thanks.

Any thoughts?

Sounds like a great idea as long as you are not loading the gun for a class action lawsuit or the DOJ.

At the request of our examiners, we created a tracking sheet. All exception loans are approved by the Loan Committee of the board, and all exception loans are listed on the Excel spreadsheet.

The sheet indicates the particulars of the loan (number, name, date, amount) and the reason(s) why the loan is considered to be an exception.

If memory serves me correctly, the reason for the tracking was a safety and soundness concern. That is, the examiners wanted us to track exception loans to see if the payment performance was worse on those than on non-exception loans.