HMDA LAR Pre-Submission Audit

It covers a pre-filing review of sampled HMDA Loan/Application Register entries against the underlying loan files. The template walks through scope and sample selection, data reconciliation, applicant and property validation, pricing and underwriting fields, and final submission readiness. It is designed to surface discrepancies before the CFPB filing deadline, not to replace your full HMDA compliance program.

Use it before each annual HMDA filing, and again after any major data cleanup or system conversion if your team wants a second validation pass. Many lenders also run a mid-cycle internal review on a smaller sample to catch recurring data-entry issues earlier. The right cadence depends on loan volume, staffing, and how much manual mapping exists between LOS, underwriting, and HMDA reporting.

A compliance analyst, HMDA specialist, quality control reviewer, or internal audit staff member usually runs it, with loan operations or secondary review support when discrepancies need file-level clarification. The reviewer should understand HMDA data fields, source document hierarchy, and how to trace a reported value back to the loan file. If your process includes sign-off, the final approver should be independent from the original data entry where possible.

Yes, it is built for pre-submission validation of HMDA LAR data and supports the kind of file-to-record reconciliation expected under CFPB HMDA reporting requirements. It also fits well with broader compliance management and quality control practices used in lending operations. The template does not replace legal review, but it helps document that reported fields were checked against source records before filing.

Common findings include mismatched application dates, incorrect action taken codes, unsupported occupancy or loan purpose fields, missing census tract data, and pricing fields that do not match the final terms. Teams also catch incorrect applicant demographic reporting, inconsistent lien status, and unresolved overrides that were never documented in the file. These are the kinds of issues that can create filing defects if they are not corrected before submission.

Use a sample that is representative of the HMDA population for the submission year, with enough coverage across product types, channels, and edge cases to expose recurring errors. The template includes fields to record the sample size and selection method so the review is auditable. If your institution has a formal QC methodology, align the sample approach to that policy and document any targeted selections separately.

Yes, you can add institution-specific fields such as reviewer hierarchy, escalation contacts, defect severity, or a link to your corrective action tracker. You can also tailor the sample logic to focus on high-risk products, manual underwriting, or loans with pricing exceptions. The core structure should stay intact so the audit still traces each reported HMDA field back to the source file.

Ad hoc checks often miss scope documentation, reviewer accountability, and follow-up on unresolved defects. This template gives you a repeatable audit trail: what was sampled, what was checked, what failed, who owns the fix, and whether the corrected record was rechecked. That makes it easier to defend the filing process internally and to spot patterns across reporting cycles.