400,000 Reasons to get HMDA Reporting "right" in 2012!
Wednesday, February 22nd, 2012 | ||
Covered Topics:
Review questions: Q: When will the HMDA "Getting it Right Guide" for 2012 become available? A: The FFIEC released the 2011 HMDA "Getting it Right Guide" on May 6, 2011. Yes, it was made available five months after the reporting year began in 2011. The Consumer Financial Protection Bureau will be making changes to the Guide and should post it on their website. Any guess about when it will become available in 2012? Until that time rely on the 2011 Guide. Q: When do regulators assess civil money penalties for HMDA reporting violations? A: The CMP's may be assessed for one or more of these reasons: 1) Failure to report accurate data; 2) failure to report the LAR in a timely manner; 3) failure to comply with previous orders to correct data; 4) repeat violations under HMDA. Q: What are three negative impacts that can result from data errors in HMDA reporting? A: The three potential negative impacts are: 1) the appearance of discriminatory lending (the HMDA LAR is also publicly available information; 2) Inaccurate conclusions (Your bank should be performing some basic analysis of HMDA data for fair lending and CRA compliance); 3) Possible resubmission of the HMDA LAR (this is time-consuming and may result in civil money penalties by your regulator). |
Presenter - Susan Costonis Susan Costonis is a compliance consultant and trainer. She also has an affiliation with gettechnical inc. as an associate trainer. Her 33 year career in banking and training began with 20 years at First National Bank, in Fort Collins, CO. Susan has been a bank compliance consultant or compliance officer in Louisiana since 1998. During her career, Susan has successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve.Susan brings decades of banking experience to the seminars that she presents and has a gift for explaining complex regulations with examples that are easy to understand. Her sense of humor and enthusiasm make the fast-paced classes fun AND effective. As a consultant, Susan has helped banks to recover from enforcement actions by implementing effective compliance programs, developing Fair Lending strategies, and receive positive CRA evaluations by developing CRA "context reports". Susan regularly presents compliance seminars to bank or credit union associations in several states. Susan is a Certified Regulatory Compliance Manager and completed the ABA Graduate Compliance School. Susan also graduated from the University of Akron with a B.S in Art Education and the Graduate Banking School of the University of Colorado. |
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Susan Costonis is a compliance consultant and trainer. She also has an affiliation with gettechnical inc. as an associate trainer. Her 33 year career in banking and training began with 20 years at First National Bank, in Fort Collins, CO. Susan has been a bank compliance consultant or compliance officer in Louisiana since 1998. During her career, Susan has successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve.