HMDA SUBMISSION DEADLINE - END OF THE QUARTER OR END OF THE YEAR?
Do we need to have the quarterly data finalized within 15, 30, 90 days, etc. after the end of the quarter or we can submit all the data after the end of the year? Is there a deadline then? Where can I get some information on this to be sure that I do not miss the deadline? Thank you for your help!
HMDA's annual submission of data to your regulator is due by March 1st of the year following the data's year. So, 2005 data is due to your regulator by 3/1/06. HMDA does require you to keep your data up-to-date on a quarterly basis (I believe it's by 30 days after the end of the quarter). I've never had current year's data requested during that year, but I think it's possible and only can be requested by your regulator(?). Others can only request your data after you have done your annual submission.
Reg C requires that 30 days after the end of the quarter a covered institution must have available a Quarterly LAR. It should be noted since this is a work in progress validity errors will / could be present on the file and it is acceptable. Quarterly updates. Regulation C requires quarterly updates of the LAR. A covered institution must record a transaction on the LAR within thirty days after the end of the calendar quarter in which final action on the transaction is taken (such as origination or purchase of a loan, or denial of an application). Your regulator may require you to update the data more frequently than Regulation C requires. Yearly LAR submissions Reg C mandates that a covered institution will prepare and submit to their regulator a year-end LAR that is Validity clean by March 1st following the calendar year of the loan data. The easiest Q&A book on HMDA would be "HMDA Getting It Right" available from the FFIEC website and is a free download.