Has anyone else experienced this problem? Below is the text of my email response to HMDAHELP@frb.gov.

On February 17, 2006 our institution submitted its 2005 HMDA LAR. On 2/21/06 we received the edit report requiring a response by 2/24/06.

In reviewing the edit report, we realized that a very small number of errors would require us to resubmit our LAR. We submitted a “2005 complete resubmission” on 2/22/06. On that same day we received the email notification from hmdasub@frb.gov stating that our resubmission had been received.

Today we received a fax stating that our response to our edit report is overdue. The original edit report states that a required response or a 2005 complete resubmission was required by 2/24/06. Since we did a “2005 complete resubmission” I was under the understanding that we have complied.



What further action do I need to take? Should I have also responded to the edit report stating that we were executing a resubmission? Please let us know as soon as possible so that we may comply.

I would also respond to the edit report that you resubmitted...my guess is that you are working with 2 different groups of people that may not be communicating. This should hopefully clear up your issue. Good luck.

Thanks--I faxed a copy of the email along with the first few pages of the edit report to the number given just a few minutes ago. This is making me paranoid.

I would suggest that you share this information with your primary regulator. The FRB performs this function for the federal banking agencies. When you experience these kinds of issues, your regulator can likely intervene on your behalf to resolve the issue.

I think I read somewhere that there was specific wording you needed to put in the subject line when you resubmitted so they would know it was a resubmission.

It says to put "2005 complete resubmission" in the subject line. This is what we did, so that shouldn't be the issue.

Just face it, they have done lost it over there in DC.

This thing seems to worsen by the week. Here's the latest email I had to send to HMDAHELP.
To Whom It May Concern:

This is to express concern with the inconsistencies experienced during the HMDA data submission process.

On 2/17/06 we submitted our HMDA LAR (we did receive the confirmation email that day). On 2/21/06 we received the edit report requiring a response by 2/24/06.

In reviewing the edit report, we realized that a very small number of errors would require us to resubmit. We executed a 2005 complete resubmission on 2/22/06 (and received the confirmation email that day).

Then on 3/1/06, we received a fax stating that our edit report was overdue. We believe we should not have received this notice, as our resubmission was submitted before the 2/24/06 deadline. After receiving the fax, we faxed notification of the situation to 202-452-6497 and emailed the situation to HMDAHELP@frbog.frb.gov. We have fax records that show this fax went successfully.

On 3/7/06, we received our edit report (requiring a response by 3/10/06) from our 2005 complete resubmission. We verified the edit report, signed the confirmation sheet, and faxed these two items to 202-452-6497 that same day (3/7/06).

However, on 3/10/06 we received an email (with the edit report attached) stating that our edit report “needs response” and directing us to fax our edit report to 202-736-5516 to the attention of “Matthew”. Upon receipt of this email, we faxed the edit report and signed confirmation sheet to the number and attention as directed. This fax was sent 3/13/06 and our fax records show that the fax went successfully. At this time we also emailed the HMDAHELP@frbog.frb.gov again with the situation.

Today, we have received yet another fax stating that our edit report is “past due.” We are extremely frustrated considering we have successfully faxed the verified edit report and signed confirmation sheet to two different numbers as directed.

We are now re-faxing to the 202-452-6497 number as directed in this latest fax from the HMDA Operations Unit. However, we are respectfully requesting that the operations flow in the HMDA Operations Unit be evaluated to determine why the above situations transpired. Our institution takes HMDA compliance seriously and believes we have taken all appropriate steps to satisfy the deadlines that Regulation C and the HMDA Operations Unit has set.

Thanks for your consideration in this matter.

If it is any consolation, I have heard of other institutions that have received conflicting instructions on their HMDA Submissions.

Hey, I still haven't received my first edit report. I think they forgot us.

I finally got notice today that they received my edit report and signed confirmation sheet. I felt like I had been handed a gold nugget or something. I think I'll have a better weekend now.