HMDA Assessment and HMDA Scrub
Client Overview
Industry: Banking
Client Type: Top 5 Depository
Project Duration: 8 Weeks
Project Date: Summer 2024
Project Scope
A large regional bank enlisted Newbold's expertise to assess its Home Mortgage Disclosure Act (HMDA) practices and review files to verify the accuracy of data on the bank’s loan application register (LAR). This project encompassed an evaluation of all cross-border mortgage lending practices and programs for both refinance and purchase transactions.
Our Approach
Newbold assembled a team of HMDA subject matter experts to undertake the assessment. Our approach included:
Documentation Review
- Comprehensive analysis of the client's credit evaluation and extension process.
- Examination of all relevant documentation, including policies, procedures, process documentation, and internal reporting.
Comprehensive Testing
- Detailed testing of specific application/loan populations to identify the extent of HMDA-related issues.
File Review
- Scrutiny of approximately 300 files, including both approved and denied applications.
- Comparison of reported data on the LAR with origination documents to ensure accuracy.
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The Results
Newbold's HMDA subject matter experts identified several critical areas of concern and weakness. Our final report detailed these issues and included actionable recommendations for remediation. The client implemented these recommendations, leading to:
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Enhanced HMDA program strength.
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Significant reduction in reporting errors.
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Improved accuracy and compliance in HMDA data reporting.
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