2021
CFPB Gives Guidance on Census Tract Boundaries for 2021 and 2022 Data
The CFPB just release a statement to give guidance on what census tract boundaries to use for both 2021 and 2022 HMDA data. The guidance is basically the same as it has been for each decennial census in the past. Here is their text: In February 2021, the U.S. Census Bureau released the 2020 Census Data tract boundaries. As a reminder, Regulation C, 12 CFR 1003.4(a)(9)(ii)(C) requires financial institutions to provide census tract information for certain properties. To determine what to report for this data point, a covered financial institution must look to the "most recent decennial census conducted by the U.S. Census Bureau" and "use the boundaries and codes in effect on January 1 of the calendar year covered by the loan/application register that it is reporting." As a…
CFPB, DOJ and OCC Take Action Against Trustmark National Bank for Deliberate Discrimination Against Black and Hispanic Families
Trustmark to Pay $5 Million Penalty and $3.85 Million to Increase Mortgage Credit Access in Memphis Neighborhoods Impacted by Redlining WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ), in cooperation with the Office of the Comptroller of the Currency (OCC), took action today to put an end to alleged redlining by Trustmark National Bank. The CFPB and DOJ allege that Trustmark discriminated against Black and Hispanic neighborhoods by deliberately not marketing, offering, or originating home loans to consumers in majority-Black and Hispanic neighborhoods in the Memphis metropolitan area. The allegations and figures below come from the CFPB announcement of 22 October 2021 and the consent order in United States v. Trustmark…
Small Business Regulatory Enforcement Fairness Act SBREFA (1071)
On September 1, 2021, the Consumer Financial Protection Bureau (CFPB) published its Summary of Proposed Rulemaking in regards to changes to the Small Business Regulatory Enforcement Fairness Act (SBREFA) as dictated under section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Under the proposed changes, lenders will be required to compile, maintain, and submit the type and purpose of the loan, the census tract for the applicant's principal place of business, and the race, sex, and ethnicity of the principal owners of the business, along with a number of other data points. RATA has reviewed the proposed rulemaking and found that this will coexist perfectly within Comply as a separate SBREFA component alongside CRA and HMDA, and believe that Comply…
Version 20.11 is available for download
We have just released a 20.11 version of Comply that is now available for download. This version incorporates all of the earlier 20 releases and includes a number of changes and enhancements that we felt would be useful to some clients. We will be releasing our main submission release of Comply 21.0 sometime in the beginning of November which will contain all of these changes and many more. Based on your update procedures, some of you may want to wait for that release to update. Please check the Change Log and/or Changes document on the Start Page of Comply to see all of the changes. That should help you and your team determine if this interim update should be installed at your institution. If you do want to install this update, you can download it from our support site at your…
2020 HMDA Peer Data Official Release is Available
Added on June 25, 2021 The CFPB has released the official 2020 national HMDA peer data as of June 17th. RATA downloaded the data and quickly began formatting it for use in the Comply software, making sure to match all Institution IDs with the preliminary data release on April 7th. By ensuring that the Institution IDs align with one another between these sets of data, all Peer Institution Groups created with the preliminary data will continue to work the same as before. It is the CFPB's intent to periodically release updates to the 2020 HMDA data based upon re-submissions, late submission etc. and we intend to review the extent of any changes in 3 months' time to see if any updates are warranted. During the conversion process, differences were noted between the preliminary data and the…
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