Section 1071 Q&As post nine

Section 1071 does not contain any reference to a mandatory resubmission of Section 1071 if the error rate exceeds a specific threshold. Is there a mandatory resubmission standard of a HMDA LAR when a filer exceeds a specific error rate?

No, a Bureau attorney in response to this question submitted by GeoDataVision explicitly stated to Len Suzio, President of GeoDataVision, that there is no standard error rate that mandates the refiling of 1071 data as long as the filing institution acts in good faith. There will be a "grace period" that covers data submitted for the first time by any reporter during which the error rate will be inconsequential as long as the filer is acting in good faith.  The Bureau attorney said the matter of a mandatory resubmission was deliberately not addressed in the Rule nor the Official Interpretation. He said however, that a decision about that may be made by "Supervision" at some time in the future (likely after a few years of reported data which may factor into the decision).


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