Right now HMDA reporting banks across the nation are checking, double-checking, scrubbing and reviewing their HMDA data. Some will find errors. Correcting errors before the data has been submitted to your regulator is a fairly easy task. But when examiners, auditors or others find errors in data previously submitted to regulators how do you correct those prior year errors?
Assume your calendar year 2010 HMDA data was submitted on schedule by March 1, 2011. During a compliance exam in the summer of 2011 examiners find discrepancies in your 2010 HMDA data. They recommended resubmission of your 2010 HMDA data. A few questions might come to mind as you prepare your resubmission:
- How do I resubmit HMDA data?
- What is the cutoff date for resubmitting my HMDA data?
- Will there be any penalties for resubmitting my HMDA data?
You are expected to submit valid and accurate HMDA data that have been verified using the FFIEC HMDA edits for a particular calendar year. However, if your institution’s initial HMDA submission contained errors, you can correct the HMDA file and send a complete, error-free resubmission. Just follow these steps:
- Open the FFIEC HMDA Data Entry Software for the applicable year of reporting.
- Update your institution’s HMDA data file with the corrections. Perform a “Batch Edit” and ensure all validity errors are corrected and quality edits are verified.
- Submit data using the preferred export option – Submission via Web. Other export options are “To Regulatory Agency via Internet e-mail” (for encrypted submissions) or “To Regulatory Agency via Postal Service” (for mailing Diskette/DVD-ROMs).
- Receive the HMDA Edit Report via e-mail from HMDAHELP@frb.gov and verify all data as correct.
- Sign and return the HMDA Edit Report Confirmation Sheet.
Once you open the FFIEC HMDA Data Entry Software, it identifies whether you are making an initial or subsequent transmission. At the successful completion of the data transmission, you receive a “Transmission Successful” message. This message contains pertinent submission information. When using the Submission via Web option, there is no need to identify the transmission as “initial” or “resubmission” because the HMDA data processing system will automatically recognize the status. If your resubmission was received after mid-April and there was not enough time to complete all processing tasks to ensure that the corrected data was included in the creation of the initial disclosure reports, the data will be processed at an appropriate time and the institution’s disclosure report will be recreated. The recreated disclosure report will be e-mailed directly to the institution for public disclosure. However, it WILL NOT post to the FFIEC HMDA website.
The deadline to receive and process a complete resubmission is two years following the activity year, generally during the fourth quarter. For example, 2009 complete resubmissions were accepted and processed into the beginning of the fourth quarter of 2011. Complete resubmissions for 2010 data will be accepted and processed until the fourth quarter of 2012, and complete resubmissions for 2011 data will be accepted and processed until the fourth quarter of 2013. The exact cut-off date for processing 2010 and 2011 HMDA data will be announced in 2012 and 2013, respectively.
You did have errors in your submitted data, so penalties are a possibility. Questions about a violation of the reporting requirements and civil money penalties should be directed to your supervisory agency. For more details on the resubmission process, refer to the Submissions and Resubmissions section of the Frequently Asked Questions (FAQs) (available at www.ffiec.gov/Hmda/faqtech.htm#srs).