RATA

A fair lending examination is more predictable than it feels, because the procedure examiners follow is published. The Interagency Fair Lending Examination Procedures set out how scope is decided, what documents get requested, how a focal point is chosen, how files are compared, and what an institution's explanation has to establish to resolve a finding. If you know that sequence, you can assemble most of what will be asked for before it is asked for. This article walks the sequence in order. It is the counterpart to our guide to running a self-assessment, which covers testing yourself. This one covers what happens when someone else does the testing. The document, and which agencies use it The procedures were issued in August 2009 by the OCC, the FDIC, the Federal Reserve Board, the…

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Fair lending examination does not stop at the credit decision. A servicer that grants a forbearance to one borrower and denies it to a similarly situated borrower on a prohibited basis has a fair lending problem, even though no application was declined and nothing about it will ever appear on a HMDA loan application register. The CFPB instructs its examiners to test for precisely this. The data they need to do it does not live in your LAR. This article covers what those servicing decisions are, why origination-side testing cannot see them, and how the statistical methodology used on application data transfers to servicing data. It is also specific about where that methodology stops transferring cleanly, because that is the part most treatments of this topic skip. What fair servicing…

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A financial institution is a covered institution under Section 1071 if it originated at least 1,000 covered credit transactions to small businesses in each of the last two calendar years, where a small business is one with gross annual revenue of $1 million or less. Both numbers changed on May 1, 2026, when the CFPB published a reconsideration final rule that raised the origination threshold from 100 and lowered the revenue ceiling from $5 million. If your institution is testing scope against the older figures, the test is wrong, not just outdated. The rule's definition of a small business, and where the revenue threshold sits Section 1071 of the Dodd-Frank Act only counts credit extended to a "small business," and the definition is entirely about gross annual revenue: $1 million or…

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This past weekend marked an exciting milestone for RATA and our clients. With the latest RATA Hosted Services (RHS) release, the first wave of ComplyBI functionality is now available to all RHS clients. This isn't just another software update. It marks the beginning of a new era in compliance analytics. For decades, compliance professionals have relied on static reports, spreadsheets, and manual analysis to understand their data. ComplyBI changes that by transforming compliance information into dynamic, interactive intelligence that helps you identify trends, uncover risk, and gain deeper insight into your institution's compliance performance. Unlike generic business intelligence tools, ComplyBI is RATA's proprietary analytics platform, designed specifically for regulatory compliance.…

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Since the release of Comply 25.0 in late October, our development team has continued enhancing the Comply Suite with new features, performance improvements, and stability updates. We are pleased to announce that Comply 25.1 is now available. Highlights of this Release Introducing ComplyBI – A powerful new business intelligence and analytics component of the Comply Suite. ComplyBI provides interactive dashboards, visual analytics, and executive reporting for HMDA, CRA, and Small Business Lending (SBL) data, helping you gain deeper insight into your compliance information than ever before.Enhanced Mapping Technology – Comply has been upgraded to the latest MapSuite technology, delivering improved mapping performance, greater stability, and integration with the Open Maps base…

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