If you are a Small Filer for HMDA, there is a laundry list of data fields you are not required to report.
There are seven fields; however, that if you voluntarily report some of the information in that field, you must report all the information relative to that field. For example, if you are going to report the credit score, then you have to also report the scoring model that it came from. Just because you report the credit score, though, doesn’t mean you have to report the reasons for denial. It’s not like you’re required to go all-in on all the data. It’s just if you go in on any of those seven, then you have to give all the corresponding data for that specific field.
Check out the video as Dave gives more information on other Small Filer reporting issues. Specifically, reporting NA, reasons for denial, property address, collecting but not reporting certain fields, etc.
These are the kinds of things we will cover at our “HMDA Data for Small Filers” webinar on March 28, 2019. We’re going to spend one hour going line by line and getting into the weeds about the data you are exempt from as well as the data you’re still required to report. See you then!
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.