#37: I Failed My CRA Data Integrity Exam – Now What?

Take a deep breath. There is life after a failed CRA data integrity exam. I’ve been through a few rough ones over the past 27 years, and every bank ends up with a stronger program as a result. While I can’t promise a smooth path forward, I can offer a few quick tips to help you get to the root cause. First of all, you will want to identify the type of error that occurred: human or systemic. This will likely have been identified by the examiners, but if not, you will need to diagnose this right away, so you can start to understand which control points to focus on first. Then you will need to determine if the errors are isolated to a certain loan product or a certain line of business like small business or HMDA. Once you have determined the root cause, you will need to act fast!It’s important to review the end-to-end process of accepting a loan application all the way through to origination. If you have a data integrity issue, be sure to bring together a CRA data working group to drive short- and long-term solutions. Lack of data integrity delays CRA examinations, causing costly rescrubbing efforts often with the support of outsourced and expensive consulting firms. Revisit your control points to determine your root cause and your path to remediation.Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm