The official 2010 Demographic Data released last month by the FFIEC is now available to all Comply users. If you are using the Auto-Updates feature of Comply, the update will automatically download to your system and you'll just need to apply it. If you are not using Auto-Updates, the update is available on the RATA Support Site at https://support.rataassociates.com/. For users running Comply version 7.7 or higher, applying the new demographics file either way will re-link the geocodes with the new demographics and re-calculate the FFIEC Borrower Income.

IMPORTANT - If you are running version 7.6 of Comply, you must perform two additional steps after applying the 2010 Demographics file to your system:

1. Re-link all geocodes in the 2010 report year. Highlight one Reporting Entity at a time and go to ‘Tools > Geocoding > Link Applications > Link all applications’.
2. Re-calculate the FFIEC fields in order to update the FFIEC Borrower Income for all applications. This will re-calculate the FFIEC fields for the entire system: ‘System > System Maintenance > Enter Advanced Option Code > 399519 > OK’.

Again, the steps above only need to be done if you are running Comply 7.6. If you are running 7.7 or higher these steps will be done automatically during the update of the demographic file.

As most of you are aware, the Financial Reform Bill has passed both the House and the Senate as of July 15^th and is waiting to be signed into law by the President in the very near future. Although this Bill was created to “fix” Wall Street, it encompasses much more and a portion of it affects HMDA, CRA and Fair Lending.

We just want to let you know that RATA Associates is aware of the changes to the regulations and we will be working diligently to update the RATA Comply software to deal with all aspects of these changes well before they go into effect.

First, it looks like the government will be creating a new division to oversee HMDA and CRA called Bureau of Consumer Financial Protection. We are not sure what affect this will have on the current regulatory agencies or the FFIEC.

At one point, the government had language in the Bill to have institutions geocode all Deposit accounts, ATM’s and Branches and have institutions submit that data on an annual basis. It looks as though that language has been taken out of the final Bill.

However, what remains affects both CRA and HMDA data collection and submission. Section 1071 of the Bill deals with the CRA changes. Most of these changes have to do with expanding the data that is collected for Small Business lending to determine if the business applying for credit is a woman or minority-owned business. The biggest change here will be the additional collection of Race, Sex and Ethnicity fields which are currently prohibited. It also looks as though the scope of CRA will be extended to include Credit Unions.

With regards to HMDA reporting, the additional fields are substantial and look to be mostly related to the additional fields normally collected for Fair Lending analysis. Changes to HMDA are specified in Section 1094, and include but are not limited to, the collection of Age (section 3 subsection A paragraph i), the collection of Points and Fees (section 5 subsection A), rate spread (section 5 subsection B), term in months of any prepayment penalty (section 5 subsection C), appraised value (section 6 subsection A), fixed loan term (section 6 subsection B), “the presence of contractual terms or proposed contractual terms that would allow the mortgagor or applicant to make payments other than fully amortizing payments during any portion of the loan term” (section 6 subsection C), full loan term (section 6 subsection D), “the channel through which application was made, including retail, broker, and other relevant categories” (section 6 subsection E), the parcel number (section 6 subsection H) and the credit score (section 6 subsection I).

Additional data collection requirements are not specified in the bill as provided, but a clause at the end of Title X states “The Bureau of Consumer Financial Protection will also include an Office for Financial Education and an Office the Financial Protection of Older Americans. In addition, Title X provides for enhanced data collection required by HMDA and ECOA.”

From what we can tell, these changes will be finalized over the next few months and will actually go into effect January 1^st, 2012. The good news is that RATA has most of the new fields readily available in the RATA Comply software already. The harder part will be on your end trying to get the data into origination systems and exported to the RATA system.

If you hear any further updates along the way or have an questions or comments, please do not hesitate to call.

In order to perform this new update you will need to be using SQL Server 2005 or higher and you must be running .NET 3.5.  If you are using SQL Express or MSDN, we have "free" upgraded versions available for you if needed.  With these new changes, the system will no longer run under Windows 2000.  We have notified all clients on multiple occasions over the last year that this change was coming and most if not all clients are ready for the new technical requirements. If you have any questions, please call for technical assistance. 

The Comply 7.8 update also contains our full release of the optional Comply Fair Lending – Advanced Analysis and Regression component.  With this newest component, institutions now have the ability to create and run both multi-linear and logistical regression against their data to identify statistically significant risk areas.  This newest component compliments the base Fair Lending component, which runs data through the FFIEC risk factors and produces “scorecards” that identify high risk disparities. Both components can help institutions identify applications that need to be reviewed by way of Comparative File Review (CFR) and then perform that function directly in Comply. 

Fair Lending is a very hot topic with regulators right now.  Find out how these new Comply components can help you reduce the time, cost and compliance burdens associates with Fair Lending at an extremely cost-effective price.  If you don't have this component, you should really look into purchasing.

Full details of what is new or changed in Comply 7.8 will be available in our Comply 7.8 Changes document which will be available at the time of release.  Once available, the update will be downloadable from our Support Site.  Please call 407-831-7282 if you have any questions or comments, would like to see a demo of either Comply Fair Lending component or would like to place an order.  Operators are standing by… 

Now the spotlight changes from data collection, clean-up and submission to analyzing your data, and Fair Lending Risk is the hot topic in the industry.  Are you lending equally to prohibited basis groups? Are you making different decision or offering different pricing based on age, race, sex, etc… ?  Do you have a way to tell if you have disparities between prohibited and non-prohibited basis borrowers?  Every institution that does lending should have two things minimum in place for Fair Lending, 1) well documented and up-to-date policies and procedures, and 2) a means to track and analyze data to make sure the policies and procedures are working.  The penalties for Fair Lending violations can be significant!

The good news is that RATA’s Comply Fair Lending module(s) can help.  RATA offers two levels of Fair Lending Analysis to help institutions of every size and skill level.  For smaller institutions with minimal volumes we offer Comply Fair Lending, which actually makes screening for statistically significant disparities easy.  With Comply Fair Lending you can import all of your HMDA and additional Fair Lending data, run scorecards on all of the key government risk factors, drill down into the data and perform Comparative File Reviews on similarly situated applications with different outcomes to see if you have Fair Lending issues or if the differences are justified.  Without Comply Fair Lending this task is extremely time consuming and would not be anywhere as thorough.  What could take a few days in Comply, could take months to try and do manually and with unproven results.

For larger institutions or institutions with staffing that that understand statistics RATA also offers a more advanced Fair Lending module that offers more advanced tools for performing Regression Analysis and all of the tasks associated with Regression.  With Comply Advanced Analysis and Regression, you get all of the Data Mining Functionality that the Comply Fair Lending offers plus, tools for normalizing your date, identifying outliers and other data that may skew results, organizing data and ultimately creating models and running Regression on your data.  You can then run Comparative File Reviews on the data that had significant deviations from the predicted outcomes.

Regulators are putting more emphasis on this type of analysis and if your institution is unable to perform this type of analysis you may be putting your institution at extreme risk.  Call RATA today at 407-831-7282 or email jaw@rataassociates.comand find out more information on how Comply Fair Lending and/or Comply Advanced Analysis and Regression can help you.  You are only a simple order form away from peace of mind.

One of the biggest changes to the Comply 7.6 Update is that it contains the new Rate Calculation methods that will need to be used starting October 1^st of this year.  The 7.6 version will download the weekly Rate Tables and will use the correct calculation automatically based on the date of the applications.  The only extra field needed by the institution is the Amortization Type and that field is already available for import if you are using Comply 7.5 or higher.  Once you start bringing in that field, Comply will take care of the rest.

With the release of Comply 7.5, institutions had access to our new Auto-Pilot Scheduler.  With Auto-pilot, institutions can fully automate all of their daily processing tasks.  So rather than repeat the same tasks monthly, quarterly or however often you process your data, Comply does the work for you.  Not only does this reduce processing time, but it standardizes the process so that it is always done the same way!  In version 7.6, we have expanded the Auto-Pilot capabilities to now also run reports.  You tell Comply what reports to run and when to run them and Comply does the rest.  It can filter data, run reports by assessment areas and much more.

The Auto-Pilot functionality was enabled for everyone to try out until July 31^st which has now passed.  If you would like to try the new features out, we can activate your license for a trial period.  Simply contact Angela Strater at 407-831-7282.  We can still offer you the special pricing if you sign up before August 31^st, 2009.

There have been many other enhancements, fixes and new features added and we will publish a changes document next week that lists everything that was done between Comply 7.5 and this newest version.

Comply 8.0 will be released sometime in the first quarter of 2010.  Most institutions will upgrade to 8.0 after submission.  Just a reminder, the Comply 8.0 systems will no longer run under Windows2000 and will require SQL Server 2005 or higher.  This only affects a few of you and with this amount of lead time, you should have no problems upgrading.  If you have technical questions feel free to have your IT departments call us. 

We think you will enjoy the changes we have made to Comply 7.6.  Please feel free to call us with any questions, comments or concerns.

Thank you.

 This system update contains many minor code modifications and also a few new fields and features.  One of the new fields in 7.5 is an additional field (Amortization Type) that is required to calculate the new Rate Spread changes that go into effect in October.  Although the Rate Spread calculator itself will not be updated until the middle of July, this should give you plenty of time to add the new field to your Origination System exports and modify the Comply Import Definitions.  We will post a Comply 7.5 changes document in the Resources section of the Start Page so that you can review all of the changes and prioritize the update.

The new Comply Auto-Pilot is now available in Comply 7.5!  The Comply Auto-Pilot is an automated Task Manager and Scheduler that can do all of the HMDA/CRA processing for you.  Jobs can be defined and run from within Comply or remotely from a server.  We are offering all current Comply users the Comply Auto-Pilot for the rest of 2009 for only $497.50.  That after that it will be $995 per year for the remainder of your active contract.   New customers will be paying $1,495 for the optional component.

To show you just how useful and powerful the Auto-Pilot is, we are offering you a free trial until July 31, 2009.  When you install the Comply 7.5 update, simply re-register Comply and the Auto-Pilot features will be active.  We will be sending you a letter, order form and invoice in the next couple of days.  Once you decide you want to keep Auto-Pilot simply execute the order form and process the invoice.  It’s that simple!

Over the next few months we will be adding new functionality to the Auto-Pilot to make it even more powerful.   Once you order it, you will get all of the new features and functionality at no additional charge.

Feel free to call us if you have any questions or comments or need help getting started.  We look forward to hearing from you.

One of the biggest changes in Comply 7.5 is the availability of our new Comply Auto-Pilot Task Manager and Scheduler. Auto-Pilot is an optional tool that has been highly requested by most of our clients and is now finally available. With the optional Auto-Pilot module, you can set up jobs to:

• Import data
• Run Edit Checks
• Calculate Rate Spreads
• Geocode
• Make Global corrections to your data
• And much more!

You can do all of the above and more without even being at your computer. With Auto-Pilot's flexible Scheduler, you can set the frequency you want to process your data down to the exact day and time.

We are going to give all of you Auto-Pilot to try free until June 30^th. After that you can purchase this important tool at a special reduced introductory price. We will be releasing more detailed information regarding Auto-Pilot's functionality and the special pricing offer in the next couple of weeks, so keep an eye out. If you have any immediate questions simply call us.

We look forward to releasing 7.5 shortly.

Thank you.

The new Rate Spread calculation will be available in our version 7.6 Comply update which is scheduled for release the first or second week of July. Our Comply version 7.5 release (due out 5/15/2009) will have the new Amortization Type Field implemented so that you can begin to modify your current import files and Import Definitions, but it will not calculate the new Rate Spread since it only affects applications with Action Dates after October 1, 2009.

On May 11, 2009 RATA Associates will be releasing the Comply Auto-pilot.  The Auto-pilot will be a paid option that users can purchase to run Comply in an automated mode.

With the Comply Auto-pilot you can set up scripts to run any Comply functionality automatically at scheduled times.  For instance, you can set up a script to grab your extract file from your operating system monthly from a specified path, Import the data using the appropriate Import Definition, then Calculate Rate Spreads, Geocode the file and run the Edit checks.  When you come in that morning everything will already be done. 

Additionally, you will be able to create Filters of data, make Global Changes to the data, Export data and with Auto-Pilot II in October run any and all reports using the new Report Definitions that will be available in 8.0.

The capabilities listed above are just a portion of what can be done with Auto-Pilot.  Auto-pilot Definitions can be set up in minutes using easy to follow Wizards to guide you through the steps.  Auto-pilot is like having a Compliance Assistant that works 24 hrs. a day, that doesn't take sick days or vacations, doesn't need benefits and is available at a fraction of the cost of a human!

Auto-pilot will be available for a special pre-order price to all existing clients for only $995 for a limited time.  The retail price after the special offer will be $1,495 for 2009 and $1,995 in 2010.  If you lock into the $995 special offer pricing, we will lock you into that price for the remainder of your current contract.  The $ 995 price will only be offered until April 15^th.  All we need by that date is a completed order form for Angela and she will invoice you for the $995, it's that simple. 

If you haven't installed Comply 7.11 or 7.12, hold off for this update because it includes the other two updates plus the new 7.13 features.  If you have not upgraded to Comply 7.1, you will have to do that update as a pre-requisite.