New to CRA here and not sure what to do...hope there is someone out there that might help. Examiners are to be here soon and I think the old CRA Officer was submitting bad data. For instance, over reporting corporate credit cards, including those instances where only new plastic was issued (when there was a alert that the card/account might be compromised or lost/stolen). Plus, they reported each individual cardholder account rather than the amount extended to the company on a given day.

Right now, I am thinking it would be best to resubmit the data before the examiners come and make us. Can anyone share their thoughts? Would it look poorly to resubmit data now that they would be reviewing next month? I am taking the perspective that it would be better to fix the problem and own up to it, than wait and possibly have it be an issue during the exam.

Any thoughts would be greatly appreciated!

Aloha, aloha. I would definitely start a serious scrub of prior year data (as far back as you believe the data to be incorrect and/or whatever is feasible) and resubmit when you are sure the data is corrected.

Geez, sorry to hear about this, that's tough to walk into a situation like that. Maybe you can come out looking like the hero in the long run.

I can't believe no one is helping out here with suggestions.

Have you made a course of action decision yet?

If you have found a material error in the CRA data that you reported you definitely should correct it and resubmit. We had a client bank who had just such a problem that was discovered as we were doing their annual CRA performance review. They hadn't reported about 25% of their SBIZ loans. They actually debated whether to resubmit. We advised them that willful cover up of a known material reporting error was a very very serious issue. They finally did resubmit. During their CRA exam 6 months later they actually received an outstanding performance rating. The correction of the mistake did not hurt their performance review as they had anticipated.

Hi MB Guy, I too thought there would be more guru help here and can not thank you enought for sharing your thoughts on the matter.

I am leaning towards resubmission. I was even prior to the posting the question on BOL. I wanted to see what other CRA Officers might think and if anyone had been through a similar situation with some experience to share.

I am kind of disappointed that there was not more folks with feedback.

What resource should we be reviewing to determine if what we have identified is a material error?

We're a national bank regulated by the OCC. We are not completely certain that the errors noted would exceed the tolerance levels. But I am leaning in the direction of, it is wrong and it is a significant portion of the this one product type, so why not just resubmit the data and be ready to explain once they walk through the door for their reviews.

Ultimately, I would like our proactive efforts to fix and report the information correctly (by resubmitting) and for this to be looked upon as just that. Of course, this is all done while hoping that the examiners would not be adding a not so nice comment in our exam. They are coming in at this time for data verification purposes and then they'll soon after be returning to complete the actual CRA PE.

Any additional thoughts? Thank you for your feedback. It is very much appreciated.

I think I would do a thorough scrub and see what the numbers look like. THen I would discuss it with my examiner. Since the disclosures are already published, refiling really won't make a difference since the disclosures won't be changed to reflect your corrected info.

However, having your data corrected internally is important since that is what the examiners will be using for their analysis.

I agree with KC. Scrub your data and see where you end up. Then discuss it with your examiner. It is much much better to find your bank's errors and correct them than to have an examiner point it out to you. If you identify the problem and correct it if necessary before the exam, your rating will not be affected. If the examiners come in and find the data is bad, they will not be able to go forward until it is corrected.

Is the OCC coming in first for the "data integrity" portion of the exam? Check your data and then, if your findings comfirm what you suspect, talk to them. You will have a much smoother data integrity and compliance exam!

I agree 100% with Kaybee.

Speaking as a former examiner with the OCC who has conducted a data integrity review, if you suspect any flaw in your data please scrub your data. If your data is found to be flawed, the wheel stops turning and no one is happy.

Aloha! Yes, there are tolerance levels, but you are already counting on using them, what would happen if the examiners found additional errors?

Kaybee is correct as is everyone. You are given a less than 4% error rate in the data. If the known issue scare you what about the unknown ones. Scrub and refile