We all know that it is time to start thinking about the HMDA changes coming next year. But, with all the preparations you may be starting related to implementation of the new requirements, don’t forget you will need to do some follow-up after the dust has settled to make sure you are “getting it right”.
What does this mean? It means you should plan on some kind of audit of your systems, processes and data entry output to ensure the end result meets HMDA requirements. For some of you, HMDA will be a brand new (and guaranteed to be confusing!) process, while for others it will mean significant changes to existing HMDA processes. In either case, it will be critical to determine quickly whether your systems and procedures are working the way you need them to. You can’t afford to wait until year end when you start your quality control reviews prior to filing to find out you had some major gaps in your processes.
Plan now to schedule an audit soon after the rule takes effect. You should ensure that you have enough data for an appropriate review, but don’t wait so long that any corrective actions would be a time consuming process to address.
This audit can be performed in-house if you have someone who is knowledgeable about the new HMDA changes (uh oh, does that sound like I’m talking about you?) or you can outsource this audit and have it taken care of quickly.
Either way, it will be very important that you don’t forget this critical step in the new rule implementation process. It’s the only way to be sure you are “getting it right”.