Added on December 28, 2017
December 22, 2018 It's been a major issue for our industry. In fact, one of our feature stories for the December magazine, written by our Managing Editor Sarah Wheeler, details the new risks HMDA reporting represents for lenders. And earlier this year HousingWire warned lenders that if they think compliance is hard now, just wait until the new HMDA regulations kick in. Most of the 2015 updates to HMDA take effect in January 2018. However, now, both the Office of the Comptroller of the Currency and the Consumer Financial Protection Bureau — both now led by Trump-administration leaders (more, below) — announced they will not be assessing penalties on HMDA data collected in 2018 and reported in 2019. What's more, the CFPB also intends to open a rulemaking to reconsider…
Added on December 28, 2017
December 21, 2018 HMDA, which was originally enacted in 1975, requires many lenders to report information with respect to applications they receive for certain types of mortgage loans and certain loans that they purchase. The Dodd-Frank Wall Street Reform and Consumer Protection Act directed the Bureau to expand the data collected and reported under HMDA to include additional information regarding, for example, mortgage loan underwriting and pricing, and authorized the Bureau to require other data. To that end, the Bureau issued a rule in 2015 that requires financial institutions to collect and report additional mortgage information beginning on January 1, 2018. In August 2017, the Bureau issued a final rule making technical corrections, clarifying certain reporting…
Added on December 22, 2017
The FFIEC released the geography changes for 2018 reporting on December 21st which incorporates changes made by the Office of Management and Budget as published on August 15, 2017. The change involves the creation of a new Metropolitan Statistical Area, 46300 - Twin Falls, ID which consists of 5 census tracts in Jerome County and 16 census tracts in Twin Falls County. This is the only geographical change for 2018 as part of the annual geography updates. This update is being released as a Demographic Data update to Comply for the 2018 reporting year and should be applied to your system before 2018 data collection begins. If you have any questions please feel free to contact us.
Added on November 7, 2017
The CFPB has announced in various documents that it will be developing and making available a new geocoder to help reduce the geocoding burden and theoretically standardize geocoding results. They already had the FFIEC geocoder that could have been used for this, but apparently they believe they can do better than that. They have even said that institutions who use this geocoder will receive safe harbor if their product gives the wrong result. If that is the case, institutions will definitely want to use that geocoder whenever possible. To make sure that institutions can take advantage of this safe harbor and also get the best geocoding results possible for addresses the CFPB can't hit, RATA will be incorporating the CFPB geocoder into our processes. With RATA's cloud-based geocoding…
Added on October 9, 2017
Comply 17.04 is now available for download. This version incorporates all of the earlier 17 releases and should be implemented for your 2017 submission. The CFPB made a few more tweaks to the 2018 Edits and we wanted to get those changes in along with a few subtle issues that were discovered at a couple of client sites. As usual, check the changes document to see what has changed to decide if you want to apply this update and the priority for your institution. You can download it from our support site to update at your convenience https://support.rataassociates.com/dl_installs.asp. Please have patience with us as the 2018 HMDA changes are implemented. We are trying to keep up with the CFPB, but they are changing and editing the specifications almost daily. Once you have updated to the…
Added on October 2, 2017
Updated Monday, October 2, 2017. The 2016 Peer data is now available on the Peer-2-Peer website. The 2016 Peer data for DataMine will be available later today. The Peer-2-Peer product is a web-based tool designed to help you understand how your institution is lending compared to specific peers or the rest of the industry. The Peer tool can help you see Summary Lending data for any submitting institution as well as Ranking reports and Market Share reports. It is a great way to put your analysis into perspective! Check out www.hmdapeer.com or www.crapeer.com to login to the peer tool. Peer data is also available for use in the Comply DataMine tool. This allows institutions to create Excel pivot tables and custom reports with the peer data and also compare it to your current HMDA data. To…
Added on September 7, 2017
The forecast track for major Hurricane Irma is showing that the eye will pass very close if not directly over the RATA facility in Longwood, FL. While our building is built to hurricane standards and we have redundant systems for power, internet connectivity may go down and be down for some time. This would affect Comply auto-updates as well as Comply registration services. During any outage, files which require geocoding can be uploaded to the RATA support website (support.rataassociates.com). This server is co-located outside of Florida and will be unaffected by the hurricane. Files will be processed and returned via the support website until any infrastructure outages are resolved at our Longwood facility. In preparation of the impact Irma may have on our facility, we will be closing…
Added on September 1, 2017
The much-anticipated Comply 17 is now complete, QA tested and ready for download. This update is mandatory for doing the 2017 submission as it contains the new CFPB HMDA.TXT format that is needed in order to upload to the CFPB submission portal. This version also contains all of the 2018 HMDA changes and new fields. When you install, the 2018 year will be available and you can start bringing in that data when ready. We have even added all of the 2018 edits that were released just 2 weeks ago. The CFPB will be making many modifications to the edits over the coming year so these will be a work in progress, but what we have is a great first start. Some of the key changes in Comply 17: Ability to create 2017 Submission in new HMDA.TXT format; this is the first year they are doing a…
Added on July 27, 2017
RATA Associates is pleased to announce that the 2017 FFIEC demographic data that is now based on the 2015 ACS is now available for all RATA Clients. If you use Auto-Updates to keep your system data up to date, you should see the new data available the next time you log in to Comply. If you don't use Auto-Updates the data will be available on the RATA Support Site to download and import. Comply links the demographics to the geocoding in the system so once you update your system all new reports and views of the data are retroactive for the entire year. For those of you using our QuickPoint Web Service (QPWS) to geocode applications real-time in your LOS systems, you will only receive the new demographics from today forward since they are sent at the time the geocode is assigned. Again, this…
Added on July 14, 2017
The
initial release of the validity and quality edits for HMDA 2018 reporting have
been released by the CFPB. There are a total of 105 validity and 41 quality
edits in the current documentation which can be found here:
https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf
We will incorporate these edits into Comply 17 which we expect to officially release in the middle of August.
Added on June 21, 2017
The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency today announced the availability of the 2017 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration under the community development definition. Distressed nonmetropolitan middle-income geographies and underserved nonmetropolitan middle-income geographies are designated by the agencies in accordance with their CRA regulations. The criteria for designating these areas are available on the Federal Financial Institutions Examination Council (FFIEC) website (http://www.ffiec.gov/cra). The designations continue…
Added on May 10, 2017
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As of April 2017, the CFPB has updated their BISG methodology. There are two things that have changed and RATA will handle the changes in two phases. The first and biggest change is that they have started to use the 2010 Census name table whereas up until now it was the 2000 Census name table (see details of counts below). This change increased the number of surnames in the table by about 10% and in running tests it seemed to reduce the Surname Not Found rate by about 10%, so it is a pretty significant improvement. The new name table has been created and tested for Comply and will be released via Auto-Updates today. For clients not using Auto-Updates for system data the file will also be available on the support site. The second update to the BISG process is much less significant but will…
Added on May 8, 2017
Comply 2018 HMDA Changes, Progress and Schedule The implementation of the CFPB 2018 HMDA changes is now about a year and a half away. The new changes will more than double the number of reportable HMDA data fields that institutions must collect, edit and submit. In analyzing the new fields that were added to the HMDA requirement, we have identified 14 fields that presently exist within RATA Comply HMDA/CRA and 39 fields that will need to be created. The new fields to be added are for automated underwriting, expanded race and ethnicity as well as general loan and property data points. New Format The submission format for the 2016 data will be unchanged from the last few years. The 2017 submissions will contain the exact same data but they will be wanting to receive it in the new…
Added on April 19, 2017
The RATA Comply Suite is currently the most robust compliance product on the market. Over the last few years we have been adding extensive amounts of functionality to help institutions streamline their processes. As part of our ongoing efforts to improve your RATA Comply experience with the products and services we provide, we have launched the RATA Customer Care Review campaign to make sure you are aware of the functionality you have and that you are using it to its full extent. By appointment we would like to have a web meeting with your entire team to discuss: Your current processes Review the Comply components that you currently have Discuss any issues or challenges you are having related to HMDA/CRA, Fair Lending or Peer Analysis Discuss any questions you have regarding the 2018…
Added on April 13, 2017
Today we released a proposal to amend Regulation C to provide certain clarifications that would help companies comply with their data reporting requirements. Regulation C implements the Home Mortgage Disclosure Act (HMDA). The Home Mortgage Disclosure Act (HMDA) requires many financial institutions to maintain, report, and publicly disclose information about mortgages. HMDA was originally enacted by Congress in 1975. These public data are important because they help show whether lenders are serving the housing needs of their communities; they give public officials information that helps them make decisions and policies; and they shed light on lending patterns that could be discriminatory. In October 2015, the Bureau issued the 2015 HMDA Final Rule, after a multi-year policy…
Added on April 13, 2017
Proposal Would Clarify Requirements and Help Companies Comply WASHINGTON, D.C. – The Consumer Financial Protection Bureau (CFPB) today issued a proposal to facilitate compliance with the 2015 updates to the Home Mortgage Disclosure Act (HMDA) rule. The changes proposed today would help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. "The Home Mortgage Disclosure Act shines a much-needed spotlight on the mortgage market, which is the largest consumer financial market in the world," said CFPB Director Richard Cordray. "Today's proposal reflects the Bureau's ongoing and substantive engagement with stakeholders in the marketplace, and will help industry meet its new reporting…
Added on April 12, 2017
As promised, we are releasing a special beta version of Comply 17, so that institutions can get a handle on where RATA is at with the changes and begin testing imports with the new data elements, if they are at that point. For those of you that just need to make sure RATA is on top of the changes, we have included a video that illustrates the new fields and imports to show you that it is implemented and works great. We have gone from 40 fields to 110 submittable fields so data collection will be a fun process. For those of you not familiar with the field changes and values, please download the 2018 File Specifications at https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf. The government has still not released the 2018 Edit Checks so really all…
Added on March 24, 2017
Proposed Rule Would Also Aid in Adoption of New Forms WASHINGTON, D.C. – The Consumer Financial Protection Bureau (CFPB) today released a proposal to amend Equal Credit Opportunity Act regulations to provide additional flexibility for mortgage lenders in the collection of consumer ethnicity and race information. The CFPB believes the proposed amendments will provide greater clarity to lenders regarding their obligations under the law, while promoting compliance with rules intended to ensure consumers are treated fairly. "This law is a key part of the government's commitment to root out discrimination," said CFPB Director Richard Cordray. "This proposal will help industry comply with the law and help protect consumers against illegal discrimination." The Equal Credit…
Added on March 15, 2017
Bureau's $1.75 Million Civil Penalty for Persistent and Substantial Reporting Errors is the CFPB's Largest Penalty to Date for HMDA Violations WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today ordered Nationstar Mortgage LLC to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014. Today's action is the largest HMDA civil penalty imposed by the Bureau to date, which stems from Nationstar's market size, the substantial magnitude of its errors, and its history of previous violations. In fact, Nationstar had been on notice since 2011 of HMDA compliance problems. In addition to paying the civil penalty, Nationstar must take the…
Added on February 17, 2017
We are pleased to announce the availability of Comply 16.11. Both the full and update versions of the installation are available on the RATA Support site. This is not a critical update and it does not require an immediate update. It does however have a lot of new features, functionality and fixes that could be helpful to the end users. We will be posting a changes document that will give you full details as to what has changed so you can decide the timeframe for updating. If you have any questions or need assistance, please contact us at 407-831-7282. Here is a list of some of the major improvements to this version: Changes to the way Geographic Areas are stored. Areas can now be stored for multi years. Many Datamine enhancements. Added Small Business and Farm Demographics to make PE…
Added on February 9, 2017
We are finalizing and QA testing our Comply 16.1 release and should have it ready by February 17th.We have made many improvements to DataMine and Audit that we had wanted to add from the beginning, but simply didn't have time to get into version 16. We have also made changes to the way we store Geographic Areas and Peer groups to better deal with multiple years in preparation for multi-year analysis in the future. In addition, we are adding new Business and Farm demographics to help with evaluating Performance Evaluation data. The RATA Business and Farm census data will now help institutions look at their business and farm lending and compare their it to the percentages of all businesses in their areas broken down by low/mod/middle/upper income areas. This data is not based on D&B…
Added on February 9, 2017
It's been a little while since we posted an update on our progress regarding the 2018 changes. There hasn't been a lot of additional information released by the CFPB regarding those changes in the last 6 months. We were hoping that they would have released the edit check specifications by now, but that hasn't happened as far as we know. Since our last update, we have had many internal meetings about various ways to deal with the pending changes. We have come up with what we believe is an even better way to deal with the new data in Comply but it will take a little longer to implement. We feel the benefits outweigh a slight delay in release, and we just wanted to keep you up to date. The new release date for the import testing version of Comply 17 is now scheduled for April 2, 2017. One of…
Added on January 30, 2017
Thank you as always for using the RATA Comply software and Geocoding services to help with your HMDA and/or CRA submissions. As part of our efforts to ensure that you have the highest quality and most current geocode results for submission, we re-geocode every application that was submitted prior to January 15th to try and improve the precision codes. We then go through the file to look for improvements to any geocodes based on the precision codes and then return any improved results in the End Of Year (EOY) geocode update file. This file should be applied to your Comply system at your earliest convenience to assure that these improved results are a part of your submission to the FFIEC. The EOY update file will only affect records submitted before January 15, 2017 so if you have submitted…
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