RATA Implementing the CRA Modernization

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 identification of tracts located in a CRA desert as forthcoming from the OCC at a later point. By planning ahead for this designation, we can immediately update existing Comply 20.0 systems with the information through a simple update to the demographic data. We are planning for the addition of data collection of Community Service data in the subsequent release following Comply 20.0. This will allow for the loading of the number of hours applied to the service so that it can be quantified using the OCC's published $38 credit per hour. Unrelated to the OCC CRA changes, but useful for analysis purposes, is the addition of a Substantial Ethnicity and Substantial Gender field to the demographic data that denotes at the census tract level if the tract is predominantly Hispanic or not and whether the predominant gender is Male or Female. While the FRS and FDIC have not yet published their CRA modernization changes, it is expected that they will at some point do so; also there are forthcoming proposals out from the CFPB as related to section 1071 of the Dodd-Frank Act that will likely impact CRA as well, so stay tuned.