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HMDA Data Integrity Review
Next HMDA-LAR due March 1, 2020
Best Practice is to perform a data integrity review of the HMDA LAR prior to submission.
This is especially important if the Bank has had prior audit findings for HMDA data accuracy.
Your Bank's HMDA data is also the foundation for other compliance requirements.
The accuracy and completeness of a Bank's HMDA data is critical to fair and responsible lending risk management, as well as lending distribution analysis for both Fair Lending and Community Reinvestment Act (CRA) compliance.
3PR can assist your Bank with a HMDA LAR Data Integrity Review. 3PR offers both a Basic Data Integrity Review and a Comprehensive Data Integrity Review, depending on your Bank's needs.
3PR's Basic Data Integrity Review includes an independent review of the HMDA LAR submission key data fields to source documents, outlined in a management report indicating the percentage of errors by key data fields and exam error rate for resubmission.
3PR's Comprehensive Data Integrity Review includes the basic review, plus a review of applicable system reports and files to determine whether they are reportable.
Data integrity and accuracy in your HMDA LAR is imperative.
BSA/AML Model Validation
Model validation is the set of processes and activities intended to verify that models are performing as expected, in line with their design objectives and business uses. Effective validation helps ensure that models are sound. It also identifies potential limitations and assumptions and assesses the possible impact for the Bank. All model components, including input, processing, and reporting, will be subject to validation.
There is regulatory expectation that model validation standards from the Federal Reserve, the Office of the Comptroller of the Currency, and the FDIC be applied to all models used at any financial institution. 3PR's Model Validation Services are part of the Management Information System Audit requirements set forth in the FFIEC BSA/AML exam manual.