RATA

Did the CFPB require filers to resubmit corrected street addresses? No. Answering a RATA client in May 2023, HMDA Help said punctuation and abbreviations in street names and numbers were not what its analysis flagged, and that the guidance was sent to help filers review their data if they chose to. It was not a mandatory request for resubmission. Update 5/9/2023: Just wanted to follow up with all of you as we learn more about the address quality letter. RATA has not gotten a response to our letter yet, but one of our clients submitted a letter on their own and I think the response is worth sharing and will make many of you feel better. See below. Question from RATA Client: The email "HMDA Data Outreach: Review Data for Invalid Entries in the Street Address Field" leads me to believe that…

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Update 4/18/2023 A customer reached out to the CFPB HMDA Help and received the following reply: Hello, Thank you for reaching out for clarification! This email went out to several financial institutions that had data flagged when we ran an analysis on the Street Address field. The brief that was attached to the original email describes the types of issues that were discovered. Please use the examples of errors in the brief to review your data and resubmit if needed. We are unable to support an individual file review. Note that there is a chance that the analysis may have flagged data that is accurate resulting in false positives. If you have reviewed your data and found it to be accurate, no action is needed. Thank you, CFPB HMDA   This definition is a short-term solution to help…

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The CFPB has gotten into a pattern of releasing two versions of HMDA peer data. To get the data out quickly, they assemble the submissions and make preliminary public data available around mid March of each year. The release of the final data with full transmittal information usually comes a few months later. As with previous years, we have decided to release a non-official version of the HMDA peer data so that all of you can start doing Peer Analysis on the current data. This release uses the Modified LAR Data from the CFPB, which we have combined and reformatted. This data gives the ability to perform analysis on a preliminary basis until the official national dataset is released later this year (typically in June). We have tested to make sure the numbers look reasonable and believe…

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The CRA and HMDA 2022 submission deadline is end of business day tomorrow, Wednesday, March 1st ET. Hopefully, you are well past your submission and are recuperating from the cleanup and submission process. If however, you are still deep into preparing your submission and need RATA's assistance, simply send an email to support@rataassociates.com and we will be periodically checking in and responding if possible. If you have a more complex issue, please call first thing in the morning and we'll get you squared away. We will work with you to ensure you get your submission in on time. 

The CRA Peer, Performance Evaluation, and Market Share data are now available for use in Comply. The 2021 CRA Aggregate and Disclosure data, used for CRA Peer analysis, was released on Thursday, December 15th. This year, like the last couple of years, there was a major delay in the release of this data. This data used to be released within a month or so of the HMDA peer data, which was released on June 22nd. Although it is extremely late from the government, RATA has completed the process of converting the data for use in Comply. The name of this file is PEERCRA21. The peer data always needs to be manually downloaded from the RATA Support Site and imported into Comply, using the Import System Data function, as these files are very large in size. For this reason, we recommend that you only…

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