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…

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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…

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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…

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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…

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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…

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