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The recent settlement between Washington Federal Bank and the Consumer Finance Protection Bureau of reporting violations under the Home Mortgage Disclosure Act (HMDA) demonstrates that mortgage lenders should maintain a high level of focus on their compliance management system. In this article, we compare the bank’s earliest and most recent 2017 HMDA submissions to uncover the likely sources of the systemic reporting issues that were found by regulators and discuss what mortgage lenders can do to mitigate those issues in their own reporting systems.