The CFPB released the "preliminary" 2025 HMDA Peer data file on March 31st, which is now available in Comply. 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 to be nearly 130 institutions which needed to be looked up manually. 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 June or July, but we are…
Thank you as always for using the RATA Comply software and Geocoding services to help with your HMDA and/or CRA submissions. As part of our efforts to ensure that you have the highest quality and most current geocode results for submission, we re-geocode every application that was submitted prior to January 22nd to try and improve the precision codes. We go through the file to look for improvements to any geocodes based on the precision codes and then return any improved results in the Year-End (YE) geocode update file. This file should be applied to your Comply system at your earliest convenience to assure that these improved results are a part of your submission. The YE update file will only affect records submitted before January 22, 2026. If you have submitted more geocoding after…
The CFPB published a validity edit change as well as the removal of a quality edit for the 2026 reporting year after we released the Comply 25.0 update. In order to get these changes, as well as a few other minor bug fixes into the hands of all users before any potential quarterly 2026 submissions, we are releasing a minor 25.01 update. If you are not a quarterly reporter or are not affected by the other bug fixes noted in the Comply changes document, then there is no need to update to 25.01 as these changes will appear in our 25.1 release later in the spring. Please contact us if you have any questions.
To all RATA Hosted Services (RHS) clients, we will be installing the 25.01 update this coming weekend, so you should not have any issues.
We are pleased to announce that the latest CRA Peer, Performance Evaluation, and Market Share data are now available for use in Comply. For On-Premise Comply Users: The 2024 CRA Aggregate and Disclosure data (also known as CRA Peer Data) used for CRA Peer analysis was released by the FFIEC/CFPB on Thursday, November 13th. RATA has completed the process of downloading and converting this data for use in Comply. The file is named PEERCRA24 and will need to be manually downloaded from the RATA Support Site and imported into Comply using the Import System Data function. The CRA Performance Evaluation and Market Share data (subsets of the Peer Data) were also compiled and released. This data is required for generating specific reports in Comply, including the CRA Performance Evaluation and…
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…
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…
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…
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…
We are pleased to announce that the CRA Peer, Performance Evaluation, and Market Share data are now available for use in Comply. For On-Prem Comply Users: The 2023 CRA Aggregate and Disclosure data (also known as CRA Peer Data), used for CRA Peer analysis, was released by the FFIEC/CFPB on Monday, December 16th. RATA has completed the process of downloading and converting this data for use in Comply. The file is named PEERCRA23 and will need to be manually downloaded from the RATA Support Site and imported into Comply using the Import System Data function. The CRA Performance Evaluation and Market Share data (subsets of the Peer Data) were also compiled and released. This data is required for generating specific reports in Comply, including the CRA Performance Evaluation and Standardized…
We are happy to announce that Comply 24 is now available on our support site for download. Please note that this update is a major architectural change moving from a 32-bit application to a 64-bit application. As such, the update procedures are NOT the same as our normal update process. It is imperative that you review the Comply Version 24.0 Update Guide and fully understand the information BEFORE proceeding with the update. If you have any questions or concerns, please contact RATA support personnel prior to attempting the update. This version of Comply contains all of the latest edit and submission changes needed to submit your 2024 HMDA and CRA data. It also contains the new 2025 reporting year so you can start to collect and prepare for the 2025 submissions as well. A changes…
Please be Advised. Hurricane Milton is closing in on Florida starting Wednesday, October 9 and continuing into Thursday, October 10. RATA is prepared for the storm and there should not be any affect to client operations. Our RATA team will work remotely as long as they have power and internet. If you have a support issue, please email support@rataassociates.com, or call 407-831-7282 and try a direct extension or leave a voicemail. We will do our best to resolve your issue as quickly as possible but it may not be same day. We plan to be up to full operations on Friday, depending on power, damage and/or flooding. We appreciate your patience and understanding and apologize for any inconvenience. We will keep you posted. Thank you.
RATA Associates is pleased to announce that the 2024 FFIEC Geographic and Demographic data is now available for all RATA clients and provided via Auto-Update or the RATA support website. Comply links to the updated demographics automatically once you update your system retroactively for the entire year. Updating your Comply system is accomplished in one of three ways: If you use Auto-Update to keep your system data up-to-date, and have the system set to auto-apply updates, then there is nothing for you to do as the system will have already updated the data for you. If you use Auto-Update, but have disabled the auto-apply feature, you should see the new data available in the Auto-Update window the next time you log in to Comply. You simply need to check the box next to the file and click…
The CFPB has released the official 2023 national HMDA peer data as of July 11, 2024. RATA downloaded the data and quickly formatted it for use in the Comply software, making sure to match all Institution IDs with the preliminary data that was released on March 26. By ensuring that the Institution IDs align with one another between these sets of data, all Peer Institution Groups created with the preliminary data will continue to work the same as before. It is the CFPB's intent to potentially release updates to the 2023 HMDA data based upon re-submissions, late submissions etc. and we intend to review the extent of any changes periodically to see if updates are warranted. Installation of the Peer data is accomplished as follows: For on-premise (client site) Comply installations Download the…
We're proud to announce the release of the new RHS Dashboard! We've added this new feature for RATA Hosted Services (RHS) Administrators, giving you the ability to log on to the RATA Support website and see a complete overview of your registered users currently within RHS. Currently this is only available on the Support website, but in October with the submission release, it will be available directly within Comply. The first panel on the dashboard displays the User Statistics for your organization. On the first row you'll see two circular graphs depicting the Number of Registered Users vs the Maximum Number of Users Available, as well as Number of Online Sessions vs Concurrent Sessions Available. These graphs will automatically change colors as you get closer to your…
On January 10th, the Federal Financial Institutions Examination Council (FFIEC), in conjunction with the Consumer Financial Protection Bureau (CFPB), announced that changes to Metropolitan Statistical Areas (MSAs) and Metropolitan Divisions (MDs) published by the Office of Management and Budget (OMB) on July 21, 2023, were being adopted for the 2024 reporting year. This update also incorporates the Connecticut County-Equivalent changes published by the US Census Bureau to the Federal Register on June 6, 2022. The regulators did not do the industry any favors by announcing the adoption of these changes 10 days into the reporting year. All commercial geocoders were caught off guard by the sudden change, and are currently working to bring these changes in line for geocoding purposes, but to…
Since the release of Comply 23.0 in late October 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, which include: Auto-Update has returned to the standard secure port of 443, removing the need to whitelist and permit traffic on port 5420 Ability to create custom permission sets for SBL Ability to run custom charts and tables for SBL Additional functionality added to the Compare tool for comparing original and standardized addresses Geographic Area filtering now supports Majority and High minority tract status in addition to Substantial For more details and a complete list of changes, please see the changes document, located on the Start Page under Resources (also available on the…
We have now released the Preliminary 2023 HMDA Peer Data. The CFPB released the "preliminary" 2023 peer data file on March 25th. For some reason, they release this data without the Transmittal File that tells us who each reporter is. RATA then has to download the file, link up the Transmittal information from last year based on the LEI number with any institutions that match, and then look up any institution's LEI info on the ones that don't match. This year that happens to be about 500 institutions that we have to look up manually. The number of lookups is higher than usual this year because they lowered the exemption thresholds and more institutions were drawn into submitting HMDA data than in previous years. Again, keep in mind this is not the official final version of the peer…
In preparation for the upcoming busy months of January and February, the Comply RHS environment will be down this upcoming weekend on Saturday, December 30th, for extended maintenance to update all installations to the new 23.01 version and roll out additional servers to handle the expected increased demand.
We do not expect any problems with the rolling out of new equipment, however, due to the nature of the process, we cannot give a firm estimate of time the system will be down, but don't expect it will be more than one work day.
The CRA Peer, Performance Evaluation, and Market Share data are now available for use in Comply. The 2022 CRA Aggregate and Disclosure data, used for CRA Peer analysis, was released on Wednesday, December 20th. RATA has completed the process of converting the data for use in Comply. The name of this file is PEERCRA22 and will need to be manually downloaded from the RATA Support Site and imported into Comply, using the Import System Data function, as these files can be large and take some time to import. For this reason, we recommend that you only load the years of peer data you are actively using into Comply and remove older years' data when your analyses are completed. The CRA Performance Evaluation and Market Share data were also compiled and released. This data is used when running…
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As you are probably aware from our last few Start Page articles, the new SBL 1071 component has been included in Comply Version 23 for you to test and get familiar with. The SBL 1071 component is accessible for any and all users who want to look at the product to make sure it meets all of your needs before actually licensing the component. Once your institution installs the Comply 23 update, you should see a new SBL 1071 component in the Data Manager (see screenshot below). If you or any of your Comply users are not seeing the component, you may have to have a Comply Administrator make some updates to the user's access rights in Comply. There will be cases where users might not have access to every component in Comply based on your institution's security policies. If you find that you do…
We are happy to announce that Comply 23 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 2023 HMDA and CRA data. It also contains the new 2024 reporting year so you can start to collect and prepare for the 2024 submissions as well. Comply 23 contains two exciting new features, one being a brand new component for Small Business Lending (SBL) 1071. With this new component, all RATA clients have the ability to begin collecting and edit checking the new SBL data as required under 1071 of the Dodd-Frank Act. In this release, the component is open to all clients for your testing purposes to see that it will meet your needs. If SBL is something that your institution will need going forward,…
As announced previously, RATA is in the process of adding a new component to Comply 23 for Small Business Lending (SBL 1071). The SBL component will be very similar to the current HMDA/CRA components, as you can see from the screenshots below, and will be made available to all RATA customers to explore and test at no charge through June 2024. It will be released in phases to allow reasonable development and quality assurance time for our staff, as well as allow customers to begin testing, when they are ready. The Fall release will contain the basics for importing, data processing, and phase 1 of the edit checks. The edit checks are constantly evolving and usually change up until submission time. Everything but the actual submission should be contained in our Fall release. Submission…
The CFPB has released the official 2022 national HMDA peer data as of June 29. RATA downloaded the data and quickly formatted it for use in the Comply software, making sure to match all Institution IDs with the preliminary data that was released on July 6. By ensuring that the Institution IDs align with one another between these sets of data, all Peer Institution Groups created with the preliminary data will continue to work the same as before. It is the CFPB's intent to potentially release updates to the 2022 HMDA data based upon re-submissions, late submissions etc. and we intend to review the extent of any changes periodically to see if updates are warranted. To download the data for use in Comply, simply log in to the support site (https://support.rataassociates.com) and go to Comply…
Since the release of Comply 22.0 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, which include: Regression in Fair Lending now includes the ability to perform Marginal Effects testing Auto-Update has been rewritten as a RESTful service, replacing the SOAP web service calls. It now uses port 5420 and the new URL is https://updates.rataassociates.com:5420/Updates CRA MicroData Exports now include the option to specify another type of field header in place of the transmittal record Dashboard controls can now perform Means and other aggregate functions For more details and a complete list of changes, please see the changes document, located on the Start Page under…
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 additional address components or special characters should not be included in the street address field. If that is true, LARS for years 2020 – 2022 that were submitted on time, that contain these address components such as a comma, dash, period, etc. in the street address field; if the geocoding is correct (can be proven) will a financial…
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…
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…
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…
We are happy to announce that Comply 22 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 2022 HMDA and CRA data. It also contains the new 2023 reporting year so you can start to collect and prepare for the 2023 submissions as well. A changes document will soon be posted to the support site and made available on the Start Page so that you will know what is fixed, updated, and added to this latest version. Because this is a submission version, it is mandatory and critical that you apply this update before performing your 2022 submission. It should be installed at your earliest convenience so that there are no surprises with new or updated edit checks. RATA Hosted Services (RHS) is RATA's…
As you should be aware, a Hurricane is closing in on Florida again on Thursday, November 10th. RATA is prepared for the storm and it should not have any effect on any client operations. RATA employees will be working remotely as long as they have power and internet. If you have a support issue please email our general support@rataassociates.com. If you have a support call, you can try a direct extension or the main voicemail. Unfortunately, you may not get your issue resolved on that day but we will do our best. We apologize for any inconvenience, but it is out of our control (literally). We hope to be up to full operations on Friday, but that will depend on power, damage and flooding. We will keep you posted the best we can. Thank you.
"Hope for the best and prepare for the worst." - As you have likely become aware, the state of Florida is presently expecting the effects of Hurricane Ian. Please exercise patience in attempting to contact us for the remainder of this week. All services we provide (geocoding, Auto-Update, QPWS, RHS) will not be affected by the storm. Email may be the best form of communication during this time, as phone connections may be spotty. If you need technical support, please send an email to support@RATAassociates.com or call and leave a message. (Paul x208; Kelly x205; David x204). We will be working remotely Wednesday (September 28th) and Thursday (September 29th), and potentially Friday (September 30th) dependent upon the storm's path and movement through our area. As…
This release is the second release of the flat file. It appends the ACS fields to the previously released Redistricting demographic fields. In calendar year 2023, the 2022 FFIEC Census flat file will be updated for a third time. The missing demographic fields from the earlier releases will be backfilled with the Decennial Census Demographic and Housing Characteristics (DHC, formerly known as SF-1) files. Currently, the DHC file release is tentatively scheduled for 2023. The third and final version of the FFIEC Demographic data is now available on the RATA support site. Please read the important information below. Important note about concerns RATA has regarding the released data On August 26th, the final phased release of demographic data was published. RATA downloaded the data…
The CFPB released specifications on GitHub in October 2020 regarding changes to the derived categorization of Race, Ethnicity and Sex groupings for reporting years 2018 and up. We made a minor change to address this in the Comply version 21.1 release which affects a small percentage of data for a very specific situation. This update corrects situations where previously, if someone classified themselves as 2-Asian and 24-Japanese, we would calculate that as 2 or more minority races. The new calculation would classify this as 2-Asian. The same goes for ethnicity sub-categories. Also, if someone classifies themselves as both male and female, the sex would be calculated as Joint. We have now updated the HMDA peer data for use in Peer2Peer to use the same calculations. This data is now…
Over the next few months RATA will offer a number of free webinars to existing clients to better illustrate the power and flexibility of the Comply Suite of compliance tools. Over the years the Comply software has evolved and become even more powerful. New components and functionality have been added with each new version released and sometimes it is hard for customers to appreciate and utilize the full potential of the software. During routine support calls we have noticed that the majority of clients are doing things in ways that are not taking advantage of key features and functionality of the latest software. For these reasons, we felt it would be in the best interest for all parties involved to go through the key functions of Comply, walk through the basics…
Since the release of Comply 21.01 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, which include: Restructuring of the manner in which User Fields are stored Updates to the Combined Ethnicity, Race and Sex fields to properly use the new values added with the 2018 HMDA changes Implementation of a Geocoding Dashboard that allows clients to see in real-time both the volume of records and when they were sent to RATA for geocoding Addition of Originated and Denied variations of the Peer2Peer Dataset Comparator reports – and more… For more details and a complete list of changes, please see the changes document, located on the Start…
The CFPB has released the official 2021 national HMDA peer data as of June 16th. RATA downloaded the data and quickly formatted it for use in the Comply software, making sure to match all Institution IDs with the preliminary data that was released on March 29th. By ensuring that the Institution IDs align with one another between these sets of data, all Peer Institution Groups created with the preliminary data will continue to work the same as before. It is the CFPB's intent to potentially release updates to the 2021 HMDA data based upon re-submissions, late submissions etc. and we intend to review the extent of any changes periodically to see if updates are warranted. To download the data for use in Comply, simply log on to the support site (https://support.rataassociates.com) and go to…
As stated in the previous article (below), we have downloaded the individual 2021 Modified LAR data from the CFPB, combined it, reformatted it and merged it with last year's transmittal data for searchability. We have tested to make sure the numbers look reasonable and believe them to be correct for now, but there are normally resubmissions and changes to the "official" data that is usually released by the CFPB in June. This data can be downloaded from the RATA Support Site. Note to RHS Users: There is no action that needs to be taken on your RHS system. The temporary peer data is available in RATA Hosted Services (RHS). Important: There was an increase in the HMDA volume this year and there are now over 26 million applications and the data and will be over 16G added to your Comply…
On March 18th, the FFIEC published an alert regarding the 2022 Census and Demographic Data availability. The alert states that due to various delays, including those related to the ongoing pandemic, the release of the data for CRA and HMDA purposes was not available as planned. It further specifies a rough timeline as to when to expect each piece of the full dataset. The text from the FFIEC alert follows: Due to delays with multiple products from the U.S. Census Bureau, the FFIEC has faced challenges in releasing the 2022 FFIEC Census products. In order to respond to user needs, the FFIEC will release the various FFIEC Census products in a sequential manner as the data become available. Using the Census Redistricting Data released on August 12, 2021, the FFIEC will release a limited flat…
RATA Associates would like to wish you and your team a very Happy Holiday Season! We would also like to let you know that due to the holidays we will have limited staffing. Our offices will be closed on Friday 12/24/2021 and Friday 12/31/2021.
We would like to wish you a Merry Christmas & Happy 2022. Because you're so special.. instead of 1 card we just had to send 2! ðŸ˜Å
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(Geocoding, Mapping, Demographics and Geographic Areas) In preparation for the 2022 reporting year, we have updated our geocoding systems to return geocodes for 2022 based upon the 2020 Census Tracts, as defined by the Census Bureau. We are fully ready to return the correct tracts as soon as geocoding begins in earnest for the 2022 reporting year. As part of this update, there are several aspects that affect Comply directly as follows: A Demographic Update for the 2022 reporting year has been released. This incorporates the new 2020 Census Tracts, however, there is a caveat to this data. The demographics are not yet available from the FFIEC, so in order to keep reports and other aspects of Comply operating in the familiar fashion, we have copied forward the 2021 demographic data to the…
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…
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…
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…
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…
On September 1, 2021, the Consumer Financial Protection Bureau (CFPB) published its Summary of Proposed Rulemaking in regards to changes to the Small Business Regulatory Enforcement Fairness Act (SBREFA) as dictated under section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Under the proposed changes, lenders will be required to compile, maintain, and submit the type and purpose of the loan, the census tract for the applicant's principal place of business, and the race, sex, and ethnicity of the principal owners of the business, along with a number of other data points. RATA has reviewed the proposed rulemaking and found that this will coexist perfectly within Comply as a separate SBREFA component alongside CRA and HMDA, and believe that Comply…
We have just released a 20.11 version of Comply that is now available for download. This version incorporates all of the earlier 20 releases and includes a number of changes and enhancements that we felt would be useful to some clients. We will be releasing our main submission release of Comply 21.0 sometime in the beginning of November which will contain all of these changes and many more. Based on your update procedures, some of you may want to wait for that release to update. Please check the Change Log and/or Changes document on the Start Page of Comply to see all of the changes. That should help you and your team determine if this interim update should be installed at your institution. If you do want to install this update, you can download it from our support site at your…
Added on June 25, 2021 The CFPB has released the official 2020 national HMDA peer data as of June 17th. RATA downloaded the data and quickly began formatting it for use in the Comply software, making sure to match all Institution IDs with the preliminary data release on April 7th. By ensuring that the Institution IDs align with one another between these sets of data, all Peer Institution Groups created with the preliminary data will continue to work the same as before. It is the CFPB's intent to periodically release updates to the 2020 HMDA data based upon re-submissions, late submission etc. and we intend to review the extent of any changes in 3 months' time to see if any updates are warranted. During the conversion process, differences were noted between the preliminary data and the…
Since the release of Comply 20.01 in early December 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 once the update is applied, including: a resolution for the beeping sound some users experienced when Auto Update auto apply was enabled; the addition of QCOK reports to the CRA component; additional selections in the edit check wizard; the removal of automatic rounding for Income in CRA and HMDA; a function to identify jumbo mortgages – and many more. For more details and a complete list of changes, please see our newly-formatted changes document, located on the Start Page under Resources (also available on the support site). This new format describes the changes in more…
Hope all is going well with your HMDA and/or CRA submission(s). You have until end of day Monday, March 1st to get your files submitted and be considered "on time". If you are still processing your file or just starting, you are really pushing it to the edge. We have been eagerly awaiting your call and most likely have already attempted to contact you to see if we can help. So, if you are looking for help we have some good news and some bad news for you. First the bad news - RATA Associates is not doing "official" support over the weekend. There just hasn't been the need or demand for it this year. But, we will point you to some reference materials below that should answer most of your questions. The good news - We still have all day Monday to help you with any problems or last-minute…
Thank you as always for using the RATA Comply software and Geocoding services to help with your HMDA and/or CRA submissions. As part of our efforts to ensure that you have the highest quality and most current geocode results for submission, we re-geocode every address that was submitted prior to February. We go through the file to look for improvements to any geocodes based on the precision codes and then return any improved results in the Year-End (YE) geocode update file. This file should be applied to your Comply system at your earliest convenience to assure that these improved results are a part of your submission. The YE update file will only affect records submitted before February. If you have submitted more geocoding after that date, those records will have already been geocoded…
UPDATE: The CRA Peer, Performance Evaluation and Market Share data is now available and can be downloaded from the support site. The 2019 CRA Aggregate and Disclosure data, used for CRA Peer analysis, was finally released on Monday, December 14. This year, like the last, there was a major delay in the release of this data for some undisclosed reason. Due to the smaller volume of this data, we typically see it released a month or so prior to the HMDA data, which was released August 30. We have completed the process of converting the data for use in Comply, Comply Peer2Peer and DataMine. The name of this file is PEERCRA19. The CRA Performance Evaluation table data was also compiled and has already been released through Auto-Updates and posted to the RATA Support Website. The name of this…
Since the release of Comply 20.0 in late October, a few changes have been made that can affect your Comply experience. A fix to correct filtering made just prior to the release of Comply 20.0 inadvertently broke the Quick Set functionality. While there was a workaround for that using Global Set, the bigger issue was that it affected Automation in Fair Lending. Secondly, an issue surfaced where creating Peer HMDA entities using institutions with identical names was causing a duplication error. Lastly, just yesterday, the FFIEC published edit changes to CRA for the 2020 reporting year. While the edits do not affect submittable records, we took this opportunity to get them into the Comply 20.01 update. If your institution is interested in any of these changes or you have not installed the…
We are happy to announce that Comply 20 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 2020 HMDA and CRA data. It also contains the new 2021 reporting year so you can start to collect and prepare for the 2021 submissions as well. A changes document will be posted to the support site later today and made available on the Start Page so that you will know what is fixed, updated and added to this latest version. Because this is a submission version, it is mandatory and critical that you do this update before performing your 2020 submission and really it should be installed at your earliest convenience so that there are no surprises with the new or updated edit checks. In addition to…
The OCC published their Final Rule changes regarding modernization of CRA data collection on May 20th and there were several changes in the ruling that can affect Comply; both in the collection of CRA-reportable data as well as assessment area analysis. While most of the rule changes are a few years away from full implementation, there are some aspects that we are moving forward with now in Comply to gain some momentum. Specifically, the upcoming release of Comply 20.0 will include a geocode attribute that denotes if a geocoded loan or loan application is within a Native Land or Tribal Area. This addition, while in the spirit of the OCC changes, could be of value to CRA reporters of other agencies as well. We are also incorporating a field in the demographic data to facilitate…
RATA Associates is pleased to announce that the 2020 FFIEC demographic data is now available for all RATA Clients. If you use Auto-Updates to keep your system data up to date, you should see the new data available the next time you log in to Comply. If you don't use Auto-Updates the data will be available on the RATA Support Site to download and import. Comply links the demographics to the geocoding in the system automatically so once you update your system all new reports and views of the data are retroactive for the entire year. For those of you using our QuickPoint Web Service (QPWS) to geocode applications real-time in your LOS systems, you will only receive the new demographics from today forward since they are sent at the time the geocode is assigned. Again, this is only an issue…
The CFPB has released the 2019 national HMDA peer data as of June 24th. RATA downloaded the data and quickly began formatting it for use in the Comply software. As of today (June 29) the data is ready for release to Comply customers. RATA will not be updating the Peer website with the 2019 data. As we previously announced, we have deprecated the old Peer website and have moved all of the Peer data and analysis functionality into the Comply 19.1 software update. To download the data for use in Comply, simply go to the support.rataassociates.com site and download the 2019 HMDA Peer Data file. Then import the data into Comply using the Import System Data icon on the Home Ribbon. There is a training video to show you how to download and import the data into Comply, and there is also a Peer…
Now that submission season is officially over and many of you are now analyzing data and starting your 2020 processing, we are happy to announce that a new version of Comply (version 19.1) is now available for download on our support site support.rataassociates.com. As usual this version contains some nice enhancements and new functionality as well as fixes to previously reported issues. A full list of enhancements and fixes can be found in our Changes document but here are some of the key new features. Key New Features (in no particular order) Date Expression in the filter designer where you can filter by quarter and month without needing a year so that these filters don't need to be copied each year to use. This is very handy for setting up non-year specific filters of your data and…
As many of you may have noticed, the 2019 Modified LAR data was released by the CFPB/FFIEC on March 31st. While this information is useful for analyzing individual institution data, there is no transmittal information to help select your peer groups. If you know the name and LEI of one of your peers that you would like to analyze, you can download the individual data and load to a reporting entity in Comply. We have an Import definition that should help you with this. The National Aggregate Dataset is the data we use to populate the Peer-2-Peer system with all of the reporters' data. This data includes the necessary respondent information in addition to the LAR data itself. We have attempted in the past to utilize this early release of the data, but what we found was that the data…
Beginning January 1, 2020, the 2015 HMDA Final Rule requires quarterly reporting for financial institutions that reported a combined total of at least 60,000 applications and covered loans, excluding purchased covered loans, for the preceding calendar year. Thus, in addition to their annual data submission, these larger-volume reporters will submit HMDA data for each of the first three quarters of the year on a quarterly basis. If you meet the criteria for quarterly submissions, Comply is ready for you to begin that process. Simply follow the same processes you would for your annual submission process, perform geocoding operations, rate spread calculations, edit checks, etc... Once you are ready to submit, simply go through the submission wizard and Comply will…
Hope all is going well with your HMDA and/or CRA submission(s). You have until end of day Monday, March 2nd to get your files submitted and be considered "on time". If you are still processing your file or just starting, you are really pushing it to the edge. We have been eagerly awaiting your call and most likely have already attempted to contact you to see if we can help. So if you are looking for help we have some good news and some bad news for you. First the bad news – RATA Associates is not doing support over the weekend. There just hasn't been the need or demand for it this year. But, we will point you to some reference materials below that should answer most of your questions. The good news – We still have all day Monday to help you with any problems or last-minute…
Thank you as always for using the RATA Comply software and Geocoding services to help with your HMDA and/or CRA submissions. As part of our efforts to ensure that you have the highest quality and most current geocode results for submission, we re-geocode every application that was submitted prior to January 24th to try and improve the precision codes. We go through the file to look for improvements to any geocodes based on the precision codes and then return any improved results in the Year-End (YE) geocode update file. This file should be applied to your Comply system at your earliest convenience to assure that these improved results are a part of your submission. The YE update file will only affect records submitted before January 24, 2020. If you have submitted more geocoding after…
Rolling into 2020, RATA has unveiled our new and improved support site. The new site offers a more modern feel as well as tightened security features. Feel free to stop by support.rataassociates.com and check it out. We have migrated all of the old account information to the new site, but we did not keep the old passwords. All users, the first time they log-in, will need to reset their passwords. To do this simply click on the Forgot Password button, enter your email and the site will send you an email to enter a new password. As with all new sites, we have tested everything under normal circumstances and it all worked great, however, if you run into an issue just give us a call (407) 831-7282 and we will resolve any issues asap. Programmers are standing by.…
UPDATE: The CRA Peer, Performance Evaluation and Market share data is now available and can be downloaded from the support site. The 2018 CRA Aggregate and Disclosure data, used for CRA Peer analysis, was finally released on Monday, December 16. This year there was a major delay in the release of this data for some undisclosed reason. Due to the smaller volume of this data, we typically see it released a month or so prior to the HMDA data, which was released August 30. We have completed the process of converting the data for use in Comply's CRA Performance Evaluation tables and DataMine, as well as the Comply Peer2Peer website. The name of this file is PEERCRA18. The CRA Performance Evaluation table data has already been released through Auto-Updates and posted to the RATA Support Website…
As you have probably seen, we released Comply 19 last week and many clients have already downloaded the update. We release the "submission" version around this time each year because some clients have freezes of software installations. As with any major upgrade, there will always be a punch list of minor issues that need to be tweaked after it is released. We have now released version 19.02 which mainly contains a fix for the HMDA Agency LAR export (text qualifiers were removed as they were causing an issue when using that file to upload to the beta platform). So far nothing critical has been found but a few little things to note are listed below. We will be adding to this list if we discover new things. We will add Updated and a date to the title if we add or change content. Important…
Historically, RATA has released the PE Aggregate and Market data days after both have been released. The HMDA data was available a few months ago, so we have been waiting for the CRA data to create the tables and release the data. In past years, August has been the release month for CRA "Peer" data from the FFIEC, although in the last couple years, there have been later releases in November 2017 and October 2018. We have now surpassed those later release dates as well, with no indication as to when the data for the 2018 report year will be available. We have contacted the FFIEC on three occasions to inquire about the release schedule. Initially we were told the release would occur in the Fall, the second follow-up we were told the release would be mid-November, and now the third inquiry…
The RATA ZOOM Geocoder has been a huge help to RATA customers trying to obtain the correct geocodes or trying verify hard-to-geocode addresses. When originally programmed, we were able to take advantage of cutting-edge technology that was provided by Google. One of those tools was called Google Fusion Tables which are used for generating and visualizing the Census Tracts and ZIP Code layers on top of the map. The Fusion Tables help store large amounts of data that could be accessed on the fly with Google Maps. Unfortunately, as of today (December 3, 2019), Google has officially discontinued and shut down the Fusion Tables tool. This has led us to develop a different methodology for layering the Census Tract boundaries and labels so that we could maintain the same functionality and…
We are happy to announce that Comply 19 is now available on our support site for download. This version of Comply contains all of the latest edit changes needed to submit your 2019 HMDA and CRA data. It also contains the new 2020 reporting year so you can start to collect and prepare for the 2020 submissions as well. For the RATA customers that did more than 60,000 applications this year and have quarterly submission requirements, you will be happy to know that the Comply system is ready for that task as well. The article below has more details regarding some of the other more notable changes in this version. A document listing all of the changes for this version will be released and put in the Comply Resource tab over the next day or two. Please feel free to download and install the…
The much anticipated 2018 HMDA Peer data was finally released by the CFPB last Friday. We have finished converting the data and retro-fitting it back to the older peer format which should satisfy 98% of your Peer Analysis needs. We would have had it done yesterday, but there was a pesky storm named Dorian knocking on our door earlier this week. Anyway, you can download the peer data file (PEERHMDA18.RZ) to be used in Comply from our support site (support.rataassociates.com). Once downloaded you can import the data into Comply using the Import System Data option on the Data Manager ribbon. Once the data is imported, if you want to use it in DataMine you will need to Sync Data before running any Excel Pivot tables. You will also want to create new Peer groups and possibly Peer Reporting…
As we are sure you have all seen on the news, hurricane Dorian gave Florida quite a scare but in the end turned just in the nick of time. Thank you all for your thoughts and prayers. Because the storm stayed off shore and the impacts of the wind were negligible we have been able to come into the office pretty much as usual over the last two days. The storm has passed us and central Florida is now officially out of danger of the storm. RATA Associates is now back to full business as usual. Thank you for your patience and understanding. The forecast track for major Hurricane Dorian is showing that the eye will pass very close, if not directly over, the RATA facility in Longwood, FL. While our building is built to hurricane standards and we have a robust…
The CFPB/FFIEC has just released the 2018 National HMDA data set and transmittal info we were all waiting for at 3:00pm EST 8/30/2019. As mentioned in the earlier Start Page article below, the data will be converted and released in two flavors. The first and most useful to all clients will be the Peer (classic) format which will basically take the 2018 data and create the older 2017 format and data fields. Since the data will be exactly the same as years past, it will work with your current Comply versions with no changes as well as the peer website. Since this data will take a little massaging to get into that format and because of the pending hurricane bearing down on Central Florida, we are hoping to release the data by next Thursday, Sept. 5th. For those needing or wanting to look at…
The Comply 18.22 update is now on our support site and available for download. Our last two updates (18.21 and 18.22) contain only edit check changes. Version 18.22 includes the 4 edit changes that were released by the CFPB last week in their July 2019 FIG. The V644.2 and V648.2 edits were updated to allow code 3 for Sex of Applicant or Borrower/Co-Applicant or Co-Borrower Collected on the Basis of Visual Observation or Surname. The V696.2 and V699.1 edits were updated by removing code 17 for the five Automated Underwriting System Results fields. This update is not critical but will ensure that your edits are flagging correctly. If you'd rather wait, rest assured that these changes and much more will be available in our Fall Comply 19.00 submission release. If you are on a version prior…
When trying to install or update Comply, some customers have been getting a message "Error opening data source". This can be caused by a missing or corrupted installation of SQL Server Native Client on the user's machine. Prior to Comply v18.2, the Comply installation would use the operating system's version of OLE DB to connect to the database. However, Microsoft has deprecated these database drivers, which don't support later versions of TLS. With most customers disabling TLS 1.0, starting with v18.2 of Comply, the installation was updated to rely on a different database driver. Since these database drivers are no longer part of the operating system, Comply installs will install the SQL Server Native Client files when they are not present on a user's machine. However, there have been a…
New 3/1/2019: Missing LEI in Transmittal Causes Submission Error on Portal - It is very important to ensure that the LEI field is populated in the reporting entity transmittal properties for all HMDA reporting entities that you wish to submit for 2018 and beyond. If you create your submission file without first populating the LEI field, you will receive an error upon upload to the platform stating "In order to access the HMDA Platform, each of your institutions must have a Legal Entity Identifier (LEI)", and your submission will be rejected. If you experience this error when uploading your file, you will need to unlock your reporting entity, add your LEI to the properties, and then go through the submission wizard again, selecting the option to reset and recreate. Before uploading…
There is a new version of the Surname Probability table that is used for the Bayesian Improved Surname Geocoding (BISG) proxy methodology in Comply. We made some minor adjustments to the suppressed values in the table as per instructions in the CFPB proxy methodologies. These updated values can help increase the accuracy of the proxy calculations by less than one percent on average. You will want to update the data at your earliest convenience just to be fully up-to-date and get the best results possible. Updating the Surname table in Comply is a simple System Data import. If you use Auto Updates and the Census Bureau/Social Security Proxy Data option is checked, the new table should download automatically to be applied. This option is not normally on by default. To change it, simply go…
Microsoft is ending support for SQL 2008 and RATA is following suit. Comply 18.1 is the last Comply update that will work with SQL 2008. There are features needed for ongoing development that are only available in SQL 2012 and higher so this move is a necessity. We stopped supporting new installations using SQL 2008 with the release of Comply 17 but we have allowed updates to still use the deprecated version of SQL Server. As far as we know, most, if not all of our clients, have migrated to SQL 2012 or higher. If you are one of the few remaining die-hards, please begin preparations to migrate to a newer SQL Server environment at your earliest convenience. Contact us at (407) 831-7282 if you have any questions or need additional information.
Comply 18.1 is now available for download from the RATA Support site. This version incorporates all of the earlier 17 and 18 updates along with other beneficial changes. If you have updated to 18.01 this release is not needed for submission. However, if you can update it wouldn't hurt. Every version of Comply is always a little better than the previous. If you are updating from 18.00 or 18.01 this update should be just a normal update because all of the 18 updates conversions have already been done. If you are updating from a Comply 17 system please read all of the important Comply 18 update info below because this update will run all of the 18 updates as well. If you have questions please call. Check the changes document to see a list of all changes to decide the…
Overall the conversions from Comply 17 to Comply 18 have been very smooth. As we mentioned in the changes document and the download of Comply 18, this update performs some major transformations to the way Fair Lending data is stored, accessed and displayed. We tried to test for all permutations, but there are too many to try and duplicate. Most of the conversions have gone well but we have just been made aware of a scenario that is not converting correctly. If you have multiple period reviews with multiple workspaces under a single Reporting Entity, in certain circumstances these are not being named correctly and they are linking to incorrect data sets. Simply renaming the workspaces will not correct the issue. If you have run the update and this scenario affects your data, do not panic.…
The Federal Deposit Insurance Corporation's (FDIC) survey of branch office deposits, as of June 30, 2018 for all FDIC-insured institutions, has been converted and released for Comply users. The Summary of Deposits (SOD) annually provides deposit totals for each of the more than 88,000 domestic offices operated by more than 5,500 FDIC-insured commercial and savings banks, savings associations, and U.S. branches of foreign banks. The FDIC Summary of Deposits data is used in various CRA reports including the Performance Evaluation tables as well as in DataMine. In DataMine, users can locate branch offices in a particular geographic area and organize by tract income level for example. The data also includes the annual deposits for each branch as well as information on the parent institution…
RATA recently became aware of an issue with five demographic fields not being populated correctly when the FFIEC data was combined with the Community Development Financial Institutions and Federal Housing Finance Agency data for years 2010 to present. While these fields are seldom used by the majority of our clients, the fact that they were not properly updated necessitated that we correct the data and provide it to clients so that the correct information is available to you in the event you ever decide to utilize it. The affected fields are as follows: Investment Area Qualification (CDFI Investment Area Qualification), New Markets Tax Credit Qualification (CDFI New Market Tax Credit Qualification) Low-Income Area (FHFA LYA) Difficult Development Area (FHFA DDA) …
Comply 18.0 is now available for download from the RATA Support site. This version incorporates all of the earlier 17 releases along with other significant changes. As always, check the changes document to see a list of all changes to decide the update priority for your institution. The Comply 18 Update The Comply 18.0 release incorporates significant changes, many of which are related to the final HMDA rule as published by the Consumer Financial Protection Bureau (CFPB) on October 15, 2015 for 2018 HMDA data submission. However, a number of other exciting changes have been made throughout the Comply system. Many of these changes affect the way data is stored in the system so the update will take existing data and restructure it to work with the new methodologies going forward. Rest…
In our last Start Page Article we discussed how RATA was going to handle the 2018 submission, and more specifically, the Partial Exemption functionality. All of the submission functionality is done and working. We are now performing final Quality Assurance on that functionality as well as some major changes to mapping and the way Fair Lending data is managed. With so many changes, we are carefully going over every aspect of the software and as always, it takes a little longer than you anticipate. We said we would be releasing the software somewhere around the end of October. It is looking like we will probably need about one more week to tighten everything up to our standards. We will be hitting it hard over the next week and will have a release ready to distribute by end of day Monday,…
The 2017 CRA Peer, Performance Evaluation and Market Share data is now available and can be downloaded from the support site. It is also available on the HMDA and CRA Peer website.
The 2017 CRA Aggregate data, used for CRA Peer analysis, was finally released on Thursday, October 25. Historically this data was released in the August/September timeframe, however like last year, this year's release was delayed for some undisclosed reason. The public HMDA data was available much earlier than usual this year and we are not sure why the FFIEC takes over six months longer to produce the CRA data. We converted the data for use in Comply's CRA Performance Evaluation tables and DataMine, as well as the Comply Peer2Peer website.
The following changes will be available in Comply version 18, which is expected to be released at the end of October. On May 24, 2018, the President signed the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) into law. This resulted in a partial exemption of certain HMDA requirements for certain insured depository institutions and insured credit unions. The Consumer Financial Protection Bureau (CFPB) published its Interpretive Procedural Rule on August 30, 2018, outlining which Data Points are not required of institutions that meet the partial exemption requirements. This document is an overview of how Comply will address the partial exemption changes for any institution that meets the criteria and elects to follow the partial exemption for their HMDA submission.…
Comply 17.13 is now available for download from the RATA Support site. This version incorporates all of the earlier 17 releases and can be implemented at your earliest convenience if needed. As always, check the changes document to see a list of all changes to decide the update priority for your institution. A few clients wanted to test the 2018 submission files on the CFPB portal, so with this version we have enabled the 2018 submission functionality. However, this is not the final submission version. We will be releasing our major update and official submission version of Comply 2018 near the end of October. The CFPB just released substantial changes to the submission process for partially exempt institutions. We will be implementing those changes as well as finalizing the edits and…
The CFPB just released updated 2018 HMDA submission requirements on Friday, August 31. These changes are for the 2018 data currently being collected, and must be used on this data that will be submitted in March 2019. There are both new and modified edits, as well as requirements for partially exempt institutions. We are still digesting the information as the documentation is quite verbose, as usual. We will be adding the submission changes to our Comply 18 release which is still expected to be available by the end of October, but wanted you to know that we are aware of the changes and are actively working on them. Here is a link to the official site:…
RATA Associates is pleased to announce that the 2018 FFIEC demographic data is now available for all RATA Clients. If you use Auto-Updates to keep your system data up to date, you should see the new data available the next time you log in to Comply. If you don't use Auto-Updates the data will be available on the RATA Support Site to download and import. Please note that this is the second year that the demographic data is based on the 2015 ACS. More info on the 2015 ACS below. Comply links the demographics to the geocoding in the system automatically so once you update your system all new reports and views of the data are retroactive for the entire year. For those of you using our QuickPoint Web Service (QPWS) to geocode applications real-time in your LOS systems, you will only…
Comply 17.12 is now available for download. This version incorporates all of the earlier 17 releases and can be implemented at your earliest convenience, if needed. As always, check the changes document to see a list of all changes to decide the update priority for your institution. At the moment, we believe this new version of Comply is fully in sync with the 2018 CFPB FIG edit specifications as they have not published any changes since February.
You can download the 17.12 update from our support site: https://support.rataassociates.com/dl_installs.asp
Feel free to contact us with any questions.
Comply 17.11 is now available for download. This version incorporates all of the earlier 17 releases and can be implemented at your earliest convenience. Since our 17.1 release in March, there have been changes made to Comply that affect both CRA and HMDA reporters. For CRA reporters, the 17.1 update inadvertently ceased to round the Loan Amount, which has been corrected in this release. There have also been a couple edit changes made to correct some Validity and Quality edits as published by the CFPB, including the Q617 edit. At the moment, we believe this new version of Comply is fully in sync with the 2018 CFPB FIG edit specifications as they have not published any changes since February. As always, check the changes document to see a list of all changes to decide the update priority…
The Official 2017 Peer HMDA data is now available for Comply DataMine and the Peer-2-Peer website. The data is available on the RATA Support Site. If you downloaded and installed the pre-release version of the data, this will simply overwrite the old data. The DataMine tool allows institutions to create Excel pivot tables and custom reports with the peer data and also compare it to your current HMDA data. Once you have installed this data you will have to do a full Sync in Datamine to use it. The Peer-2-Peer product is a web-based tool designed to help you understand how your institution is lending compared to specific peers or the rest of the industry. The Peer tool can help you see Summary Lending data for any submitting institution as well as Ranking reports and Market Share reports.…
Comply 17.1 is now available for download. This version incorporates all of the earlier 17 releases and should be implemented at your earliest convenience. For the last few months the CFPB has made many updates to the 2018 FIG that affect both the data field formatting and the edits. As of this minute, we believe this new version is fully in sync with the FIG. As usual, check the changes document to see what else has changed to decide the update priority for your institution. Because much of this update has to do with 2018 FIG changes we strongly recommend that you install this version ASAP. In addition to the CFPB changes, this version has enhancements and new functionality. The biggest new feature is the introduction of our new Comply Dashboard View which allows users to create…
It has come to our attention that the CFPB is still making changes to the 2017 HMDA submission portal. We have just heard (1/9/18) that they changed the formatting of the Respondent ID field. It is now required that all institutions remove leading zeros and the hyphen for those reporters that use their Tax ID as Respondent ID. The hyphen is still required for the Tax ID field. This represents a huge hurdle for the industry because all HMDA submission tools are designed to make that field 10 digits. This was not mentioned in the 2017 FIG and did not flag as an issue when institutions uploaded test files to the HMDA Platform. Now a recent change causes a syntactical edit, S025, when leading zeros or hyphens are present in the Respondent ID field. Your submission file will not be accepted if…
December 22, 2018 It's been a major issue for our industry. In fact, one of our feature stories for the December magazine, written by our Managing Editor Sarah Wheeler, details the new risks HMDA reporting represents for lenders. And earlier this year HousingWire warned lenders that if they think compliance is hard now, just wait until the new HMDA regulations kick in. Most of the 2015 updates to HMDA take effect in January 2018. However, now, both the Office of the Comptroller of the Currency and the Consumer Financial Protection Bureau — both now led by Trump-administration leaders (more, below) — announced they will not be assessing penalties on HMDA data collected in 2018 and reported in 2019. What's more, the CFPB also intends to open a rulemaking to reconsider…
December 21, 2018 HMDA, which was originally enacted in 1975, requires many lenders to report information with respect to applications they receive for certain types of mortgage loans and certain loans that they purchase. The Dodd-Frank Wall Street Reform and Consumer Protection Act directed the Bureau to expand the data collected and reported under HMDA to include additional information regarding, for example, mortgage loan underwriting and pricing, and authorized the Bureau to require other data. To that end, the Bureau issued a rule in 2015 that requires financial institutions to collect and report additional mortgage information beginning on January 1, 2018. In August 2017, the Bureau issued a final rule making technical corrections, clarifying certain reporting…
The FFIEC released the geography changes for 2018 reporting on December 21st which incorporates changes made by the Office of Management and Budget as published on August 15, 2017. The change involves the creation of a new Metropolitan Statistical Area, 46300 - Twin Falls, ID which consists of 5 census tracts in Jerome County and 16 census tracts in Twin Falls County. This is the only geographical change for 2018 as part of the annual geography updates. This update is being released as a Demographic Data update to Comply for the 2018 reporting year and should be applied to your system before 2018 data collection begins. If you have any questions please feel free to contact us.
The CFPB has announced in various documents that it will be developing and making available a new geocoder to help reduce the geocoding burden and theoretically standardize geocoding results. They already had the FFIEC geocoder that could have been used for this, but apparently they believe they can do better than that. They have even said that institutions who use this geocoder will receive safe harbor if their product gives the wrong result. If that is the case, institutions will definitely want to use that geocoder whenever possible. To make sure that institutions can take advantage of this safe harbor and also get the best geocoding results possible for addresses the CFPB can't hit, RATA will be incorporating the CFPB geocoder into our processes. With RATA's cloud-based geocoding…
Comply 17.04 is now available for download. This version incorporates all of the earlier 17 releases and should be implemented for your 2017 submission. The CFPB made a few more tweaks to the 2018 Edits and we wanted to get those changes in along with a few subtle issues that were discovered at a couple of client sites. As usual, check the changes document to see what has changed to decide if you want to apply this update and the priority for your institution. You can download it from our support site to update at your convenience https://support.rataassociates.com/dl_installs.asp. Please have patience with us as the 2018 HMDA changes are implemented. We are trying to keep up with the CFPB, but they are changing and editing the specifications almost daily. Once you have updated to the…
Updated Monday, October 2, 2017. The 2016 Peer data is now available on the Peer-2-Peer website. The 2016 Peer data for DataMine will be available later today. The Peer-2-Peer product is a web-based tool designed to help you understand how your institution is lending compared to specific peers or the rest of the industry. The Peer tool can help you see Summary Lending data for any submitting institution as well as Ranking reports and Market Share reports. It is a great way to put your analysis into perspective! Check out www.hmdapeer.com or www.crapeer.com to login to the peer tool. Peer data is also available for use in the Comply DataMine tool. This allows institutions to create Excel pivot tables and custom reports with the peer data and also compare it to your current HMDA data. To…
The forecast track for major Hurricane Irma is showing that the eye will pass very close if not directly over the RATA facility in Longwood, FL. While our building is built to hurricane standards and we have redundant systems for power, internet connectivity may go down and be down for some time. This would affect Comply auto-updates as well as Comply registration services. During any outage, files which require geocoding can be uploaded to the RATA support website (support.rataassociates.com). This server is co-located outside of Florida and will be unaffected by the hurricane. Files will be processed and returned via the support website until any infrastructure outages are resolved at our Longwood facility. In preparation of the impact Irma may have on our facility, we will be closing…
The much-anticipated Comply 17 is now complete, QA tested and ready for download. This update is mandatory for doing the 2017 submission as it contains the new CFPB HMDA.TXT format that is needed in order to upload to the CFPB submission portal. This version also contains all of the 2018 HMDA changes and new fields. When you install, the 2018 year will be available and you can start bringing in that data when ready. We have even added all of the 2018 edits that were released just 2 weeks ago. The CFPB will be making many modifications to the edits over the coming year so these will be a work in progress, but what we have is a great first start. Some of the key changes in Comply 17: Ability to create 2017 Submission in new HMDA.TXT format; this is the first year they are doing a…
RATA Associates is pleased to announce that the 2017 FFIEC demographic data that is now based on the 2015 ACS is now available for all RATA Clients. If you use Auto-Updates to keep your system data up to date, you should see the new data available the next time you log in to Comply. If you don't use Auto-Updates the data will be available on the RATA Support Site to download and import. Comply links the demographics to the geocoding in the system so once you update your system all new reports and views of the data are retroactive for the entire year. For those of you using our QuickPoint Web Service (QPWS) to geocode applications real-time in your LOS systems, you will only receive the new demographics from today forward since they are sent at the time the geocode is assigned. Again, this…
The
initial release of the validity and quality edits for HMDA 2018 reporting have
been released by the CFPB. There are a total of 105 validity and 41 quality
edits in the current documentation which can be found here:
https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf
We will incorporate these edits into Comply 17 which we expect to officially release in the middle of August.
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As of April 2017, the CFPB has updated their BISG methodology. There are two things that have changed and RATA will handle the changes in two phases. The first and biggest change is that they have started to use the 2010 Census name table whereas up until now it was the 2000 Census name table (see details of counts below). This change increased the number of surnames in the table by about 10% and in running tests it seemed to reduce the Surname Not Found rate by about 10%, so it is a pretty significant improvement. The new name table has been created and tested for Comply and will be released via Auto-Updates today. For clients not using Auto-Updates for system data the file will also be available on the support site. The second update to the BISG process is much less significant but will…
As promised, we are releasing a special beta version of Comply 17, so that institutions can get a handle on where RATA is at with the changes and begin testing imports with the new data elements, if they are at that point. For those of you that just need to make sure RATA is on top of the changes, we have included a video that illustrates the new fields and imports to show you that it is implemented and works great. We have gone from 40 fields to 110 submittable fields so data collection will be a fun process. For those of you not familiar with the field changes and values, please download the 2018 File Specifications at https://www.consumerfinance.gov/data-research/hmda/static/for-filers/2018/2018-HMDA-FIG.pdf. The government has still not released the 2018 Edit Checks so really all…
We are pleased to announce the availability of Comply 16.11. Both the full and update versions of the installation are available on the RATA Support site. This is not a critical update and it does not require an immediate update. It does however have a lot of new features, functionality and fixes that could be helpful to the end users. We will be posting a changes document that will give you full details as to what has changed so you can decide the timeframe for updating. If you have any questions or need assistance, please contact us at 407-831-7282. Here is a list of some of the major improvements to this version: Changes to the way Geographic Areas are stored. Areas can now be stored for multi years. Many Datamine enhancements. Added Small Business and Farm Demographics to make PE…
We are finalizing and QA testing our Comply 16.1 release and should have it ready by February 17th.We have made many improvements to DataMine and Audit that we had wanted to add from the beginning, but simply didn't have time to get into version 16. We have also made changes to the way we store Geographic Areas and Peer groups to better deal with multiple years in preparation for multi-year analysis in the future. In addition, we are adding new Business and Farm demographics to help with evaluating Performance Evaluation data. The RATA Business and Farm census data will now help institutions look at their business and farm lending and compare their it to the percentages of all businesses in their areas broken down by low/mod/middle/upper income areas. This data is not based on D&B…
It's been a little while since we posted an update on our progress regarding the 2018 changes. There hasn't been a lot of additional information released by the CFPB regarding those changes in the last 6 months. We were hoping that they would have released the edit check specifications by now, but that hasn't happened as far as we know. Since our last update, we have had many internal meetings about various ways to deal with the pending changes. We have come up with what we believe is an even better way to deal with the new data in Comply but it will take a little longer to implement. We feel the benefits outweigh a slight delay in release, and we just wanted to keep you up to date. The new release date for the import testing version of Comply 17 is now scheduled for April 2, 2017. One of…
Thank you as always for using the RATA Comply software and Geocoding services to help with your HMDA and/or CRA submissions. As part of our efforts to ensure that you have the highest quality and most current geocode results for submission, we re-geocode every application that was submitted prior to January 15th to try and improve the precision codes. We then go through the file to look for improvements to any geocodes based on the precision codes and then return any improved results in the End Of Year (EOY) geocode update file. This file should be applied to your Comply system at your earliest convenience to assure that these improved results are a part of your submission to the FFIEC. The EOY update file will only affect records submitted before January 15, 2017 so if you have submitted…
As part of the upcoming 16.1 Comply release, RATA will be adding the Business and Farm data based on a census of businesses. Up to this point RATA has been using the CRA Aggregate peer business data for performance measures in our CRA Performance Evaluation reports. Many institutions have requested that we use the Business/Farm census data and we have decided to move forward with the latest data we could obtain. All reports that use this data will be offered in both the current aggregate versions and the census of businesses versions to increase your analysis options. This will be available to all customers licensed for Comply CRA at no additional charge. By adding this new data and functionality to the 16.1 release we have had to push the delivery dates of both 16.1 and the 17 beta…
As part of the upcoming HMDA changes, we are getting a lot of inquiries on two topics in particular. 1) Handling of the HMDA 2017 data submission in February 2018. There are no data changes to the HMDA 2017 data being submitted in February 2018. The only change to the HMDA 2017 submission is that the submission file itself will go from the current fixed-length record format to a pipe "|" delimited format. This change will be available in version 17 of the Comply software, to be released in 2017. 2) In regards to the Universal Loan Identifier (ULI), RATA Comply will be able to accept loans for 2018 either with or without ULI. As part of the Reporting Entity (RE) properties in Comply there will be a field for the Legal Entity ID (LEI). During the import process all loans that are not Action…
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We are pleased to announce the availability of Comply 2016. Both the full and update versions of the installation are available on the RATA Support site. We strongly recommend that you update as it contains the 2016 edit changes as well as numerous enhancements, fixes and the new optional Datamine and Audit tools. The Version 16.0 Changes document is available in the Resources section of the Comply Start page and includes highlights of the major changes. If you have any questions or need assistance, please contact us at 407-831-7282.
The new edition of the "Comply 365" newsletter has been released to give you the latest news on what's happening at RATA Associates.
Click here for the latest edition and articles...
The RATA Comply Suite is currently the most robust compliance product on the market.Over the last few years we have been adding extensive amounts of functionality to help institutions streamline their processes. As part of our ongoing efforts to improve your RATA Comply experience with the products and services we provide, we are launching a Customer Care Review campaign to make sure you are aware of the functionality you have and that you are using it to its full extent. By appointment we would like to have a web meeting with your entire team to discuss: Your current processes Review the Comply components that you currently have Discuss any issues or challenges you are having related to HMDA/CRA, Fair Lending or Peer Analysis Discuss any questions you have regarding the 2018 HMDA…
We have started a quarterly newsletter called "Comply 365" to give you the latest news on what's happening at RATA Associates.
UPDATE: 02/02/2016 The official 2018 HMDA changes document was finalized in October 2015. That document had many of the ideas that were finalized but it did not contain the technical details that we need as a software provider to implement the changes. Without the "official" enumerations for all of the new fields, and more specifically on the re-used but updated fields, it is hard for us to complete specifications for our programmers.We are currently in communication with the CFPB and are trying to get clarifications on the questions we have. Once we have these answers we are planning to implement them into Comply for the 2018 reporting years and forward. The Application screens will stay the same for all years prior to 2018 then 2018 will display the new fields and the new…
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