2017 Submission format and 2018 Universal Loan ID (ULI) information

As part of the upcoming HMDA changes, we are getting a lot of inquiries on two topics in particular.

1) Handling of the HMDA 2017 data submission in February 2018. There are no data changes to the HMDA 2017 data being submitted in February 2018. The only change to the HMDA 2017 submission is that the submission file itself will go from the current fixed-length record format to a pipe "|" delimited format. This change will be available in version 17 of the Comply software, to be released in 2017.

2) In regards to the Universal Loan Identifier (ULI), RATA Comply will be able to accept loans for 2018 either with or without ULI. As part of the Reporting Entity (RE) properties in Comply there will be a field for the Legal Entity ID (LEI). During the import process all loans that are not Action 6–Purchased will be scanned for the LEI. If the number being imported contains the LEI the import mechanism will parse out the components and put the pieces into the appropriate fields. If the app number does not contain the LEI, Comply will construct it with the LEI in the RE properties and calculate the check digit. Either way, Comply will end up with three fields for the App Number: Universal Loan ID (ULI), Legal Entity Number (LEI) and the Application Number. For Action 6–Purchased loans the system will parse and store the LEI for the originating institution. Any and all of these fields can be exported from Comply at any time as well.