RATA

We are happy to announce that Comply 25 is now available on our support site for download. This version of Comply contains all of the latest edit and submission changes needed to submit your 2025 HMDA, CRA and SBL data. It also contains the new 2026 reporting year so you can start to collect and prepare for the 2026 submissions as well. Comply 25 contains several enhancements and updates that will benefit all users. For CRA users, the encryption capability for the submission file has been updated to properly encrypt submission files in the manner that the FFIEC expects. Last year, following the 64-bit conversion, it was discovered that the encryption did not follow the FFIEC methodology in a 64-bit environment. Since this is corrected, CRA submissions should operate as expected for your…

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The CFPB has released the official 2024 national HMDA peer data as of June 26, 2025. We downloaded the data and it was immediately apparent that it was different than in past years. Specifically, the Reporter Panel file was not produced for the 2024 dataset, which contains information regarding the institution's assets, LEI, RSSD ID and Other Lender Code. We inquired with the CFPB as to when that file might be available, and were eventually told that "The HMDA Reporter Panel for 2024 is unlikely to be produced as it is out of the operational scope authorized for HMDA Operations." With the loss of the Reporter Panel file, we had to reference other data sources to attempt to fill in the pieces absent from the data. We were able to find the LEI, RSSD ID and assets for depository…

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Since the release of Comply 24.0 in mid-November of last year, our team has been actively making changes and adding features to improve your Comply experience. This version brings those changes to your system. Some of the more noteworthy changes include: New Majority Minority and High Minority reports have been added to CRA with three variations (All Loans, CRA Reportable Loans, and CRA/HMDA Reportable Loans). New Assessment Area Performance by Census Tract Racial Composition Black or African American reports have been added to Peer HMDA. This report can be run for three different categories (All Loans, Denied Loans, or Originated Loans). Several SBL edits have been modified to align with the latest FIG and correct previous issues (E0020, E0321, E2040.1, W0762, W0902, W1082, W1262, and…

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We have now released the Preliminary 2024 HMDA Peer Data.  The CFPB released the "preliminary" 2024 peer data file on March 31st. As always, this data release does not include the Transmittal File that tells us who each reporter is. RATA downloads the file, links up the Transmittal information from last year based on the LEI number with any institutions that match, and then look up any institutions' LEI information for the ones that don't match. This year that happened for nearly 150 institutions that we have to look up manually. Again, keep in mind this is not the official final version of the peer data. The official release usually contains updates to the data, late reporter data, and the official transmittal data for each institution. The official data is typically released in…

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Why Redlining Risk Should Continue to Be a Focus During the Next Administration Guest analysis. This article was written by Richard Horn of Garris Horn LLP and first published on 20 January 2025. The first-person voice throughout is the author’s, not RATA’s. Primary sources for the two settlements it discusses are the CFPB enforcement action against Draper & Kramer Mortgage Corporation (17 January 2025) and the Justice Department’s settlement with The Mortgage Firm, Inc. (7 January 2025), with the case documents on the DOJ’s United States v. The Mortgage Firm page (S.D. Fla.). Facts from the CFPB's 17 January 2025 enforcement action and the Justice Department's 7 January 2025 and 10 October 2024 announcements, as cited in this article. …

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