(a)Compliance management should update the HMDA-LAR procedures to include additional steps in identifying and validating loan applications when the customers/consumers are applying as non-natural persons and originating as consumer purpose loans secured by a primary residence (dwelling).
Compliance management should communicate updates of policies and procedures to all employees impacted by the changes.
(b)The HMDA Specialist/Supervisor should enhance the HMDA-LAR data scrubbing process performed during each quarter to include exception reporting for identifying applications that changed during the application process, and validating the accuracy and completeness of GMI-related data prior to each HMDA-LAR submission.
In addition, the
Compliance management should communicate updates of policies and procedures to all employees impacted by the changes.
(b)The HMDA Specialist/Supervisor should enhance the HMDA-LAR data scrubbing process performed during each quarter to include exception reporting for identifying applications that changed during the application process, and validating the accuracy and completeness of GMI-related data prior to each HMDA-LAR submission.
In addition, the