Regulatory Compliance
Login
THE WORKS BlogCredit Union Compliance News & Views

Antelope vs Field Mice – Where to Focus Your Efforts

Have you ever had that moment where you were overcome with hunger and thought to yourself, “Should I have the antelope or some field mice?”

No?

Okay, I admit that the thought has never crossed my mind either, but it does bring up a great point for my thought of the day. I have read and heard this analogy a few different times; that if you were a lion would you spend your time hunting field mice that can be found in abundance throughout the plain, or an antelope that is much faster but a stronger meal. Although the mice would be an easier target, the energy spent to capture and eat them would likely be more than what you would get in return. On the other hand, it may take a little more energy and effort to hunt the antelope, but the return is exponentially greater. The best part here is that this mindset can now be applied to how you approach your HMDA data (for real though, it can)!

Recently, the OCC in conjunction with the FDIC and FRB issued a bulletin to inform their respective FIs on the “key fields” they will be looking at with the new HMDA data. Now, I know the NCUA was not mentioned here, but I think we can almost assume a similar path will be taken with their approach. Out of the 110 data fields, these regulators identified 37 that they were going to focus on. In order to save space, I have included the link here.

Although it may not seem like it, this is great news for those of you responsible for this process. This will allow you to focus on bringing in that antelope, instead of the mice. I am not saying that these 37 fields are the only ones you have to worry about. What I am trying to say is focus on what is most important first. Focus on the fields that present you the most risk. I have mentioned this a thousand times – we have so much going on day-to-day that it’s important we first focus on what is vital. In order to ensure we are getting the greatest return for our efforts, we need to focus on those areas that cover the most risk.

So don’t starve yourself by focusing on every minute detail. Take a look at this list and create a game plan for covering these key fields.

Is anyone else all of a sudden hungry?

 

You may also like...