How We Source and Date What We Publish
Everything on this page is something you can check against a live article. It describes what our published material does, not what happens before it is published.
We write about regulations that carry filing obligations and examination consequences. A reader acting on a figure we published needs to know where it came from and when it was last checked. The practices below are how that is made visible, and each one links to an article demonstrating it.
Who writes these articles
Articles are published under a house byline, RATA Associates, rather than individual author names. We would rather state that plainly than attach credentials we cannot evidence on a page whose whole purpose is sourcing. Where an article was written by someone outside the firm, that is credited in the article itself — see the guest analysis by Richard Horn of Garris Horn LLP, which carries a credit and a link to the original publication.
The firm has worked on HMDA, CRA and fair lending data since 1987, which is 39 years. That is the basis on which we write about methodology; it is not a substitute for a citation, which is why the citations are there.
Primary sources, named and linked
Where an article states a regulatory requirement, it names the governing document and links to it, so the claim can be checked rather than taken on trust. Examples currently live:
- What a fair lending exam actually asks for cites the Interagency Fair Lending Examination Procedures by part and appendix, and Regulation B's commentary by section.
- Fair servicing cites the CFPB's Mortgage Servicing Examination Procedures by module and 12 CFR 1024.41 by subsection.
- The enforcement articles cite the CFPB or Justice Department action they describe, with the case or docket where one exists.
Where a document is published by an agency whose own site blocks automated retrieval, we link a government mirror of the identical document rather than a paraphrase.
Figures carry the date they were checked
Regulatory thresholds change on annual cycles, and a correct figure from two years ago is a wrong figure today. Where a page depends on rule text or published data, it states when that was last read:
- The Section 1071 coverage checker prints the date the rule text was last verified, and names the Federal Register document it is read from.
- The rate spread calculator prints the date its APOR table was pulled, names the source file, and shows the exact range of dates it covers.
- Our geocoding accuracy methodology is dated and explains how the accuracy figure is measured, rather than asserting the number alone.
Every article displays its publication date. Where a specific figure in an older article has since been checked against current rule text, the article says so at that figure rather than only at the top.
Tools decline rather than guess
A calculator on a compliance site that returns a confident wrong answer is worse than one that returns nothing. The rate spread calculator refuses any rate-lock date outside the range of the APOR data it actually holds, and routes you to the official FFIEC or CFPB calculator instead of extrapolating. The coverage checker names two questions the rule text does not settle and tells you to check the filing instructions rather than inferring them.
Corrections are made in the article
When something we published stops being true, the article is corrected where the claim sits, and says what changed. Our article on the Trustmark National Bank action now records that the consent order was vacated on 21 May 2025 and the case dismissed, because an article describing a live order that had ended would mislead a reader about current exposure.
We also say when we could not verify something. The fair servicing article states that no public enforcement action alleging discrimination in a servicing decision could be identified, rather than implying one exists, and distinguishes what regulatory guidance instructs from what it leaves unspecified.
What this material is not
These articles are a reading of published regulation and agency guidance. They are not legal advice, they are not a substitute for your own counsel or compliance function, and they do not create any relationship between you and RATA Associates. Where a question turns on your institution's specific facts, the answer is your counsel's, not ours.
Questions about a figure or a citation in anything we have published? Tell us and we will either evidence it or correct it.
