For those of you who will not have to report HMDA data after July 1, are you going to continue collecting the data as usual but just not report next year? I see a lot of benefits in continuing to collect as usual, chief among them having the data available for fair lending analysis. What is everyone else going to do and why?
Examiners will likely encourage you to continue to collect HMDA data; that makes their job much easier. If you don’t collect, examiners will need to collect HMDA-like data for a sample of the fewer than 100 loans per year originated by your institutions.
• Since your institution will no longer collect such data you will not be in a position to refute the findings from the examiner’s sample.
• You will still be required to collect GMI for each application as required by Regulation B or by the OCC’s Part 27, but will not be required to compile it in a list.
o Compiling the data puts you in position to refute examiner’s findings. If you are going to compile the data you should just continue to use the HMDA LAR; you are already familiar with the requirements.