SOLUTIONS GRADED A+
✔✔What are the two methods of omissions testing? - ✔✔Manual and systemic
omissions testing.
✔✔What is manual omissions testing? - ✔✔Reviewing files manually to identify missing
applications or loans.
✔✔What are some sources to review during manual omissions testing? - ✔✔Trial
balance reports, pipeline and sold loan reports, system reports with collateral codes,
reports of denied or non-originated loan applications.
✔✔What is systemic omissions testing? - ✔✔Reconciling reported applications and
loans to loan origination system records.
✔✔What should be done after identifying differences in systemic omissions testing? -
✔✔Determine if the differences are legitimate or if reportable applications should be
added to the LAR.
✔✔What are some items that may be on the LOS but are not HMDA reportable? -
✔✔Leads or inquiries not considered applications, records without identified address or
marked as 'TBD', records with action taken date in a different year.
✔✔What should be done with items on the LAR that are not reportable in the current
HMDA LAR reporting year? - ✔✔They should be identified and addressed during the
omissions testing process.
✔✔Why is omissions testing important? - ✔✔To ensure the completeness and data
integrity of the LAR.
✔✔What do regulators expect regarding the LAR? - ✔✔Regulators expect the LAR to
include all reportable applications.
✔✔What will examiners test regarding the LAR? - ✔✔Examiners will test the
'completeness' of the LAR.
✔✔What are some potential methods for omissions testing? - ✔✔Manual file reviews
and reviewing other available information.
✔✔What should be done if systemic omissions testing is not possible? - ✔✔Review
other available information to identify missing applications or loans.
, ✔✔What is the purpose of comparing the LAR to the loan origination system records? -
✔✔To identify any differences and determine if reportable applications should be added
to the LAR.
✔✔What should be done if differences are found during systemic omissions testing? -
✔✔Determine if the differences are legitimate or if reportable applications should be
added to the LAR.
✔✔What is the importance of defining when an inquiry or lead becomes an application?
- ✔✔To consistently determine if they are HMDA reportable.
✔✔What does TBD notation on an address indicate? - ✔✔That the record may not be
an application.
✔✔What does a different year in the action taken date indicate? - ✔✔That the record
may not be reportable in the current HMDA LAR reporting year.
✔✔What is the purpose of HMDA? - ✔✔To provide information about lending patterns
and enforce anti-discrimination regulations.
✔✔Who should understand the HMDA data and keep senior management informed? -
✔✔Compliance officers and fair and responsible lending officers.
✔✔What does HMDA data offer an unparalleled view of? - ✔✔The lending activities of
mortgage lenders.
✔✔What can analysis of HMDA data help an institution understand? - ✔✔Markets it has
penetrated and where it can maximize reach and revenue.
✔✔What are some data points used for performance analysis in HMDA? - ✔✔Race,
ethnicity, gender, age, loan profile, loan type, property location, loan acceptance/denial,
loan details, originator.
✔✔What can regulators examine using HMDA data? - ✔✔Lending patterns, fair lending
performance, compliance issues.
✔✔What are some loan profile data points used in HMDA analysis? - ✔✔Income, LTV,
DTI, AUS result, credit score.
✔✔What information is collected about loan applicants and borrowers in HMDA? -
✔✔Race, ethnicity, gender, age.