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Course description

The Home Mortgage Disclosure Act (HMDA), implemented by the Regulation C (12 CFR 1003), requires covered financial institutions to compile and disclose data about home purchase loans, home improvement loans, and refinancings that they originate or purchase, or for which they receive applications. In addition, several loan applicant/borrower characteristics must be reported.

Sounds simple doesn't it? But in the "real" world, it is anything but simple.  

What do a $92 million bank in Georgia and a $14 billion bank in Washington have in common? Unfortunately they were among the almost 6 financial institutions that were fined a total of more than $513,500 for HMDA errors in the calendar year of 2013.

In addition to those costly civil money penalties, HMDA errors can result in negative publicity, increased regulatory scrutiny, and, most frightening of all, attention from the Department of Justice. Whether an internal/external auditor, a loan officer who takes home mortgage applications, or the person responsible for the accuracy of the HMDA data, you have opportunities to either protect your financial institution from, or expose it to, HMDA problems.

This session will assist you in:  

  • Understanding the rate spreads 
  • Identifying potential HMDA applications from loan and denial files
  • Rooting out the "real story" behind withdrawn applications
  • Distinguishing between "temporary" and "short term" financing
  • Recognizing refinancings that were previously not "reportable"
  • Spotting possible errors from simply looking at the LAR
  • Verifying data accuracy against source documents
  • And more….


  • Compliance officers; 
  • Auditors; 
  • HMDA input clerks;
  • Loan officers


Partner, Cashman Compliance Solutions, LLC

Patricia Cashman

Patricia Cashman is a partner in Cashman Compliance Solutions, LLC. She is responsible for consumer compliance reviews, Bank Secrecy Act (BSA) and Anti-Money Laundering reviews, and compliance and BSA training. Patricia began her banking career in 1969. She has been the senior operations officer for three Dallas-Ft. Worth area community banks, an assistant examiner for the Texas Department of Banking and managed the compliance/internal audit division of TIB - The Independent BankersBank, one of the largest bankers' banks in the country. Additionally, Patricia has spoken as a webcast/teleconference presenter for the American Bankers Association (ABA), BankersOnline (BOL) and the Center for Financial Training (CFT), taught a variety of compliance subjects for the Texas Bankers Association (TBA) and ABA at their respective Compliance Schools. She also serves as a BOL GURU and been a speaker/trainer for numerous banks and compliance organizations.

Course curriculum

  • 1


    • Auditing HMDA

  • 2


    • Slides

    • Materials

    • LAR Worksheet

    • Questions and Answers