The Home Mortgage Disclosure Act (“HMDA”) requires that covered financial institutions submit 109 data points on each reportable mortgage transaction. HMDA data is extremely nuanced and often requires expert assistance to maintain accurate data. Accurate HMDA data is critical, as federal regulators have set allowable error thresholds that, if outside of tolerance, could require re-review and re-filing.

The criticality of data accuracy means that everyone in the financial institution must be aware of best practices and regulatory requirements surrounding each HMDA reportable field. It is of paramount importance that the first line of defense has a good understanding of the requirements, since they are the risk owners and often the ones tasked with collecting HMDA data before any second line validation occurs.

Asurity’s HMDA subject matter experts engaged with each functional area that had HMDA data collection responsibilities at the institution to understand current state practices. Concurrently, Asurity reviewed all governance documentation associated with HMDA compliance, including policies, procedures, job aids, and process maps. Using all of this information and industry best practices, Asurity developed an easy-to-understand, detailed compliance guide that contained over three dozen data points for each HMDA reportable field, including (but not limited to) acceptable data formats, controls, stakeholders, scenarios, and regulatory citations.

For ongoing maintenance of the HMDA compliance guide, Asurity developed a unique solution that would allow the client to easily update a manageable spreadsheet and, using a simple multi-step process, update the document. This functionality allows the client to gain efficiency in the editing process and establish a sustainable routine for keeping the document current.

In addition to the compliance guide, Asurity performed a review of the client’s rules logic embedded in its loan origination system to identify potential gaps and enhancements to current-state HMDA reporting. For every reportable field, Asurity reviewed the rules logic and gave the client advice on how to bolster existing processes, improve HMDA data accuracy, and leverage peer data to identify anomalous data practices.