RATA

As most of you are aware, the 2020 U.S. Census occurred two years ago. When preparing for the census, the Census Bureau redefines Census Tract boundaries based upon the estimated population of an area. After the census, these new Census Tract boundaries are updated with the demographic profile of the recorded data for that area. Typically the world moves forward with the census tract changes early in the year following the census, however, the CFPB/FFIEC typically lags by a year for HMDA/CRA purposes; they require the new data and boundaries beginning two years after the census (i.e. 2022) for purposes of data collection and submission. RATA Associates has been in the HMDA/CRA arena for over 30 years now and has been through this process twice already (1990 > 2000 and 2000 > 2010). We…

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For technical reasons and because support has ended for SQL 2012, the Comply 21 update now requires SQL Server 2014 or higher for both new installations and updates. Microsoft ended mainstream support for SQL Server 2012 on July 11, 2017, and extended support will be ending on July 12, 2022. SQL Server 2012 has inherent security issues that necessitate migration to newer versions. Comply always supports all versions of SQL Server that are in mainstream support. We will also try to support SQL Server through any extended support period as much as possible. But support for a SQL Server version cannot be guaranteed after mainstream support ends if there are potential security issues or there are important pieces of functionality that Comply requires. Mainstream support has also ended for SQL…

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IMPORTANT MESSAGE: We have identified an issue with Comply 21.0 that has necessitated a change and will result in Comply 21.01 being released tomorrow, November 17th. If you have already downloaded the Comply 21.0 update, but have not yet embarked upon installation to your production systems, it would be in your best interest to await the 21.01 update. The issue that has arisen affects the Auto-Update feature as well as import operations using Auto-Pilot. There are workarounds for the issues, but if you haven't installed yet or you can do another update we would recommend the 21.01 version. We apologize for any inconvenience this may have caused you. Please contact us if you have any questions. To all RATA Hosted Services (RHS) clients, we will be installing the 21.01 update tomorrow…

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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…

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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…

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