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RATA Associates

RATA Associates has been the trusted leader in HMDA, CRA, and Fair Lending compliance software since 1987. With nearly four decades of regulatory expertise, our team of compliance specialists helps financial institutions across the United States navigate complex reporting requirements with confidence. Our articles provide practical guidance on compliance best practices, regulatory updates, and strategies to streamline your reporting process.

Federal Financial Institutions Regulatory Agencies Announce Availability of 2014 Small Business, Small Farm, and Community Development Lending Data

August 25, 2015 RATA Associates 1 min read

The three federal banking agency members of the Federal Financial Institutions Examination Council (FFIEC) with Community Reinvestment Act (CRA) responsibilities—the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency—announced today the availability of data on small business, small farm, and community development lending reported by certain commercial banks and savings associations, pursuant to the CRA. An FFIEC disclosure statement on the reported 2014 CRA data, in electronic form, is available for each reporting commercial bank and savings association. The FFIEC also has prepared aggregate disclosure statements of small business and small farm lending for all of the metropolitan…

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Agencies release list of distressed or underserved nonmetropolitan middle-income geographies

July 8, 2015 RATA Associates 2 min read

The Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation today announced the availability of the 2015 list of distressed or underserved nonmetropolitan middle-income geographies, where revitalization or stabilization activities will receive Community Reinvestment Act (CRA) consideration as community development. 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 to reflect local…

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CFPB Orders RPM Mortgage to Pay $19 Million for Steering Consumers Into Costlier Mortgages

June 4, 2015 RATA Associates 4 min read
CFPB Orders RPM Mortgage to Pay $19 Million for Steering Consumers Into Costlier Mortgages

RPM CEO Erwin Robert Hirt to Pay Additional $1 Million Civil Penalty

WASHINGTON, D.C. – Today, the Consumer Financial Protection Bureau (CFPB) filed a complaint in federal district court against RPM Mortgage, Inc. and its CEO, Erwin Robert Hirt, for illegally paying bonuses and higher commissions to loan originators to incentivize them to steer consumers into costlier mortgages. The CFPB also filed a proposed order that, if entered by the court, would require RPM to pay $18 million in redress to consumers and a $1 million civil penalty, and would require Hirt to pay an additional $1 million civil penalty.

Facts from the CFPB's action against RPM Mortgage, Inc. and Erwin Robert Hirt, as cited in this article.
InstitutionRegulator(s)ViolationPenaltyPeriod coveredHMDA/fair-lending data field involved
RPM Mortgage, Inc.Consumer Financial Protection Bureau (CFPB)Violated the Loan Originator Compensation Rule and the Consumer Financial Protection Act (CFPA) by paying bonuses and higher commissions to loan originators to incentivize them to steer consumers into costlier mortgages$18 million in redress to consumers; $1 million civil penalty (RPM); Hirt to pay an additional $1 million civil penaltyApril 2011 through December 2013Loan officer compensation / steering

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Justice Department and CFPB Reach Settlement with Provident Funding Associates to Resolve Allegations of Mortgage Lending Discrimination

May 28, 2015 RATA Associates 5 min read
Justice Department and CFPB Reach Settlement with Provident Funding Associates to Resolve Allegations of Mortgage Lending Discrimination

Settlement Provides $9 Million in Compensation to African-American and Hispanic Borrowers

The Justice Department and Consumer Financial Protection Bureau (Bureau) filed a consent order today to resolve allegations that Provident Funding Associates (Provident) engaged in a pattern or practice of discrimination that increased loan prices for African-American and Hispanic borrowers who obtained residential mortgages between 2006 and 2011 from Provident's nationwide network of mortgage brokers.

Facts from the Justice Department and CFPB's settlement with Provident Funding Associates, as cited in this article.
InstitutionRegulator(s)ViolationPenaltyPeriod coveredHMDA/fair-lending data field involved
Provident Funding AssociatesJustice Department; Consumer Financial Protection BureauPattern or practice of discrimination that increased loan prices for African-American and Hispanic borrowers, in violation of the Fair Housing Act and Equal Credit Opportunity Act (ECOA)$9 million into a fund for the benefit of victims of the alleged discrimination2006 to 2011—

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U.S. Justice Department and North Carolina Attorney General Reach Settlement to Resolve Allegations of Auto Lending Discrimination

February 10, 2015 RATA Associates 6 min read
U.S. Justice Department and North Carolina Attorney General Reach Settlement to Resolve Allegations of Auto Lending Discrimination

Settlement Requires Substantial Improvements to Dealerships' Policies and Provides $225,000 in Relief to Affected Customers

The U.S. Department of Justice Civil Rights Division, the U.S. Attorney's Office for the Western District of North Carolina and the North Carolina Department of Justice today announced a settlement of the federal government's first-ever discrimination lawsuit involving "buy here, pay here" auto lending.  The settlement, which is subject to court approval, was filed today in the U.S. District Court for the Western District of North Carolina.

Facts from the Justice Department's settlement with Auto Fare Inc. and Southeastern Auto Corp., as cited in this article.
InstitutionRegulator(s)ViolationPenaltyPeriod coveredHMDA/fair-lending data field involved
Auto Fare Inc. and Southeastern Auto Corp.U.S. Department of Justice Civil Rights Division; U.S. Attorney's Office for the Western District of North Carolina; North Carolina Department of JusticePattern or practice of "reverse redlining" by intentionally targeting African-American customers for unfair and predatory credit practices in financing used car purchases, in violation of the federal Equal Credit Opportunity Act; also alleged violation of North Carolina's Unfair and Deceptive Trade Practices Act$225,000 settlement fund to compensate victims of past discriminatory and predatory lending—Disproportionately high sales prices, down payments, and interest rates compared to other subprime used-car dealers

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