HMDA LAR Submission. HMDA LAR Submission. If I have 500 exceptions to clean up and it is 3 PM here then in Washington DC it would be...

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1 HMDA LAR Submission HMDA LAR Submission If I have 500 exceptions to clean up and it is 3 PM here then in Washington DC it would be... 1

2 CenTrax Support When you are prepared to submit your data (or at least you think you are), you need to go back to the beginning and do some checking before you attempt to create your submission file. Downloading the Encryption Software To submit your HMDA LAR by or on the web, you must download and install the free software provided by the FFIEC. Once the software is installed, CenTrax will automatically detect the installation and launch it at the appropriate time. Download and installation instructions may be found on the FFIEC site at Verifying the Bank From the main menu select Setup, Bank Configuration. Select the Edit tab. If corrections need to be made, click Edit, make the necessary changes and then click Save. If you are FRS or FDIC regulated and are optionally including HMDA Denial Reasons, ensure that the box to Require Denials Reasons is enabled. The information on this screen must be correct. It is automatically added to the HMDA LAR as the header record. Close Bank Configuration. Note that we used a generic address here, not the of the contact person. You may want to consider this option in case the contact person is out of the office when the verification reports are returned. For those institutions that are under the CFPB, be sure to put your CFPB respondent information in the HMDA section and your primary regulator information in the CRA section. Special Circumstances for the HMDA Edits A note about edit Q067 as we prepare to run the HMDA Exceptions. This edit is triggered when the Race/Gender/Ethnicity of the borrower is NA (7/4/4) but the income is greater than zero. HMDA Getting it Right states that the income on these transactions should be zero. Changing the income to zero will trigger edit Q027. Records submitted with Q067 will cause your submission to be rejected and you will be required to refile. Records with Q027 are acceptable for these transactions. 2 Copyright Marquis Software Solutions 2013

3 Checking the Edits (one last time) HMDA LAR Submission Prior to submission, you should run the HMDA Exceptions report one last time with some specific settings (Discovery, Integrity Reports). Adding a field selection is optional. You should NOT choose to Exclude Exceptions or Exclude Geocode Edits. You SHOULD check the box to Ignore Quality Edit Verification Flags. This ensures that you will get every edit, even those that you already verified, on the report. Don t print the Summary Only, print the whole report. CenTrax Edits The CenTrax Edits for HMDA are generally related to Rate Spread reporting. You should verify this information just as you would a Quality Edit and correct as needed. A list of these edits are available in Appendix C. When you produce the final copy of your HMDA Exceptions you may choose to exclude the CenTrax edits as they will not appear on the report your regulator asks you to verify. To exclude the CenTrax edits, click Exclude Exceptions. 3

4 CenTrax Support Click Tag CenTrax and the edits will be marked for exclusion. Click Ok. Continue to run the report with your other report selections. File Wide Edits & Summary Page File Wide Edits apply to multiple records. When you encounter these on the last page of the report, it is important you verify the information and be prepared to explain why the information included in the edit is true. You will be required to provide this on your verification reports and a yes it is correct isn t sufficient. The File Wide Edits section also shows you how many records will have a reportable spread. You need to be comfortable that this number is correct before you submit, especially if you have not been checking your CenTrax edits (which are intended to help prevent the incorrect reporting of spread) through out the year. If you aren t sure, you can filter these records (look in FAST HMDA) or you can print a paper LAR to verify these records. The Summary by Exception Type is the area of the report that will be helpful when you are verifying the reports you will receive after submission. 4 Copyright Marquis Software Solutions 2013

5 HMDA LAR Submission 5

6 CenTrax Support Running the Wizard From the main menu, select Filing, HMDA Filing Wizard. Click Process to begin. If you haven t been as strict as you can with your HMDA Preferences, we will warn you. For some of you this will be because you are not opting to report HMDA Denial Reasons. Click Yes to verify these settings. You will be taken to the HMDA/CRA Preferences tab. 6 Copyright Marquis Software Solutions 2013

7 HMDA LAR Submission Verify that your Validity, Quality and CenTrax Edits are checked. If they are not we recommend you check all three options and then click Save and Close. You will be returned to the Wizard and the process begins. If no changes need to be made, click Save and Close to return to the Wizard. Please note that if you did not enable the Require Denial Reasons box in Bank Configuration, this message may also appear. Failing the Wizard This file did not successfully pass the Wizard. Any line marked with a red X indicates that you have records in that category. In this case, the file contains Validity, Quality and CenTrax edits. You cannot submit with Validity edits so you would need to return to the HMDA Exceptions Report and see what s there. A message would appear at the end of the original processing that would remind you to do this. 7

8 CenTrax Support There is one exception to the Validity Edit rule. If you have mobile home applications that you do not have a property address for you may submit NA for all 4 geocode fields. CenTrax will ALWAYS consider this a Geocode Exception but will be listed on a separate line. If you have Geocode Exceptions, and therefore by default Validity Edits, contact us here in Support and we will walk you through the rest of the process. That way we can talk it over with you and make sure everything else is okay. This file has a number of problems that need to be resolved before you can move on. Notice at the bottom that you have a Report button. If you choose to print the report, it will list the records that triggered the General Integrity Checks section. For the Geocode and Validity sections, you should run the Geocode Exceptions or HMDA Exceptions report. If you click Report on the Wizard, you will select an output for the report. Make a selection and click Ok. 8 Copyright Marquis Software Solutions 2013

9 HMDA LAR Submission What if you do not pass? If you have deleted records Deleted records must be removed from the file. From the main menu got to File, File Manager. Click Indexing. Set the button to Purge deleted records. Click Process. To continue, click Yes and then Ok. Remember, once this is complete these records cannot be recalled. Be sure to verify these records before removal. Close all open windows. 9

10 CenTrax Support If you have records not marked as HMDA Qualified These records must be located and either deleted or marked as HMDA Qualified. You can locate these records using FAST HMDA. If you return these records to the file please remember to reprocess the HMDA Exceptions Report. Go to Discovery, Research. Click FAST HMDA. Drop down the HMDA Qualified field and select No. Click Save. 10 Copyright Marquis Software Solutions 2013

11 HMDA LAR Submission Click FAST HMDA again. Drop down the HMDA Qualified field and select Und. Click Save. 11

12 CenTrax Support The two conditions are connected by and but we need to change to or. Click Swap. Click Browse. A count will appear. Click OK to accept. Go to the HMDA button. Check the HMDA Qualified field and either Delete as needed or click Edit, change the setting to Yes and then Save. If you delete records remember to run the Remove Records feature before going back to the Wizard. Use Next to continue to additional records as needed. When complete close all open windows and clear the filter. 12 Copyright Marquis Software Solutions 2013

13 HMDA LAR Submission If you have Geocode Errors or Exceptions Run the Geocode Errors & Exceptions report at Discovery, Integrity Reports, Geocode Exceptions. These should also appear on the HMDA Exceptions report. Remember, if these are mobile home loans with no property address available, you will leave them as they are and CenTrax will properly report these on the LAR. You will be required to bypass the Wizard. If you have only these records and Quality and/or CenTrax edits, exit the Wizard screen and go to Filing, Transmission File (under HMDA Filing Wizard). You can also skip ahead to that section of this document. If you have Validity Edits Run the HMDA Exceptions report at Discovery, Integrity Reports, HMDA Exceptions. Remember to check the box to Ignore Quality Edit Verification Flags. If the only validity edits are related to mobile home loans with no geocode, see the section above to bypass the Wizard. All other validity edits must be corrected. If you have Quality and/or CenTrax Edits These should have been verified by now. If you have any unverified edits please verify them now. Otherwise, it is acceptable to submit the LAR with Quality edits and some CenTrax edits. 13

14 CenTrax Support Passing the Wizard Based on the last section you now know that you can get a red X for the last 2 items and be allowed to continue to the LAR setup form. Remember, if you didn t expect the red X don t continue! Run the exceptions report and look at those records. If you did expect it and you are confident that your data has been verified and corrected as needed, click Create LAR to continue. 14 Copyright Marquis Software Solutions 2013

15 HMDA LAR Submission You will not Include Loans with No Action. You will Include Purchased Loans. If you are OCC or OTS the Show Denial Reason will be checked automatically. For everyone else, you will need to check it yourself if you want to report denial reasons. Select a Submission Type. If you plan to your submission, select Internet. For your submission due on March 1 do not check the Public LAR box. The Path to store HMDA.DAT will default to a folder created by CenTrax. If you want to change this location, click the button with 3 dots. If you plan to submit by , you will need to indicate the location of the FFIEC software. Click the button with 3 dots. Locate the software and click Select. (If you plan to submit by Internet, leave this path blank). Click Create. Note: If you didn t select the FFIEC path, you will receive a warning, click Ok to clear. 15

16 CenTrax Support You may get a message that the FFIEC software is out of date. If you know you have the most recent version, click Ok and continue. If you aren t sure, click Ok and check the FFIEC website before you continue. Next, the number of entries on your HMDA LAR will be listed. Click OK. (This number should EXACTLY match the number of records in your file.) If you are mailing your submission, click Yes when asked if you want to print your transmittal sheet. You need to mail it along with your disks/cds. If you are submitting by or Web, you can click No since it is not required for these types of submissions. 16 Copyright Marquis Software Solutions 2013

17 Encrypting for Submission If you set the FFIEC Software Path the program automatically launches. HMDA LAR Submission The first message is simply letting you know that the software isn t connecting you to the Internet. Click Ok. Click Browse to locate the DAT file. Select the drive and directory where the file was stored. Click to highlight the file and then click Open. The path is populated. Click Begin Process. 17

18 CenTrax Support The final message is displayed when the encryption is complete. Click Print to print these instructions. Follow these instructions exactly to complete the submission of the HMDA data. Once you the submission off, you should get an auto reply that indicates that the was received. This does NOT indicate that the submission was correct yet...only that they received your . If you don t get the auto reply within 24 hours you should resend the . To Send the Submission by Internet You must upload your HMDA LAR created by CenTrax to utilize this method. Locate the HMDA Data Entry Software 2013 icon and double-click to launch. 18 Copyright Marquis Software Solutions 2013

19 HMDA LAR Submission Click Import DAT. Select From External File and click OK. 19

20 CenTrax Support Click Browse to locate the LAR you created in CenTrax. Select the drive and directory where you created your LAR in CenTrax. Click to select the file and then click Open. 20 Copyright Marquis Software Solutions 2013

21 HMDA LAR Submission Click Begin. Click Ok. Click Yes. Click Ok. 21

22 CenTrax Support The FFIEC Software may require you to run the Batch Edit report to continue. Choose Batch Edit. Click Begin. 22 Copyright Marquis Software Solutions 2013

23 HMDA LAR Submission The report should complete without any errors. Click Ok. Click Front Page to return to the main menu. 23

24 CenTrax Support Click Export. Since you ran the Batch Edit report in the previous step, click Continue with Export. Choose Submission via Web and click OK. 24 Copyright Marquis Software Solutions 2013

25 HMDA LAR Submission Click Continue. Click Begin. The rest is up to you. I cannot show the final screens since I am not able to submit a real LAR, even in the interest of your education! 25

26 CenTrax Support 26 Copyright Marquis Software Solutions 2013