RATA's Customer Care Campaign
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 have launched 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 changes and RATA's plans
- Demonstrate the new Comply DataMine and Audit tools as well as any other tools you don't current utilize
- Determine any additional action items needed – training, consulting, products, services, etc.
We are already booked through September so be sure to sign up at your earliest convenience. The meetings are typically done at 2:00 EST. You can call us to schedule your appointment or go to www.rataassociates.com/customercare to see available dates and sign up yourself. If that time does not work for you at all, simply call us and we can set up a custom meeting on an available day.
Team RATA is here to help you with HMDA/CRA, Fair Lending, Regression and data analysis in any way we can. Your feedback is very important to us and will help us determine how to make the software even better. We look forward to our meeting.
New Comply DataMine Report Builder
The Comply DataMine analysis tool is RATA's new advanced custom report builder. RATA clients will now have the ability to build both custom pivot tables and custom executive reports using the power of Microsoft Excel, SQL Server Analysis Services (SSAS) and your Comply Database. With this powerful configuration you are able to create reports using combinations of your latest HMDA and CRA data, peer data, demographic data, deposit data and more.
Customers have been asking RATA for more flexible reporting options and with the release of Comply 16 in September that option will be available. This new optional component will be available for the release of the 2015 HMDA and CRA peer data and will give customers much more flexibility for analyzing their own data compared to peer data by year, geography and additional filters. Regulators have been recently creating peer groups by asset size, rate spread percentages and geography. The new Peer Group Definition Builder will enable users to create the same groups quickly and easily.
By using different Peer Group definitions, geographic definitions and other data, you will be able to explore your data by dragging and dropping the fields you want to analyze into columns or rows to slice and dice the data in seconds with interactive Excel Pivot tables.
Additionally, more advanced users can create custom executive reports and dashboard-type reports. If you don't want to create the reports yourself a RATA team member can build you a template to use for a small service fee.
The DataMine tool will ship with many templates and the amount of free templates will grow over time as we add new reports recommended by customers. Here are just a couple of samples we created, many in just minutes!
Here is a sample that was done quickly using multiple pivot tables.
Here is sample that was setup using custom formulas and more elaborate formatting.
The DataMine will be able to assist with HMDA Analysis, CRA Performance Evaluations, and Fair Lending scorecards that require peer and other data sources.
DataMine Peer Group Builder
In recent examinations multiple agency's examiners have been selecting peer institutions based on geography, asset size and filtered loan counts that are similar to the target institution. Using the Comply DataMine tool you will be able to select peers and create peer groups exactly the way the examiners do.
By walking through the Peer Group definition builder you are able to filter down to both simple and complex conditions and then select all institutions or the specific institutions that meet your criteria.
The first step would be to click Peer Institution Groups and select New. Then you simply name the Peer Group and tell the wizard what year of peer data you want to analyze.
In this screen shot we simply clicked on the search button and got all 7062 institutions for 2014. From there we can select specific institutions, all institutions, or filter further by General, Properties, Limits, Geographic definitions or Lending areas either separately or in tandem.
For example, maybe you want to analyze your institution against institutions that are closet to your asset size, by specific institutions, by regulator, or just banks closest to your origination rate within your assessment area(s).
Here is a sample of the top 10 OCC banks by originations that did at least one loan in Seminole County Florida in a detailed list view.
From here you can select all 10 institutions to start building your peer group, select and add specific institutions from the list to add to your group and more. From the detail group list you can sort by any column, export the list to Excel or a text file, print the list and more.
You can create as many different Peer Group definitions as you want for all of your peer analysis needs. Once they are created they are fully accessible by the Comply DataMine tool as shown below.
Within a couple minutes we are able to build a simple table that shows the Top 10 OCC submitters in our Test for Comply 365 Peer group compared to all submitters and broken down by action taken.
Again, this is just a very simplistic example of the power of the DataMine Tool and the Peer Group definition builder!
Analyzing Redlining with Peer Data like a Regulator
In working directly with customers and our Fair Lending consulting companies using Comply Fair Lending we have seen some new types of analysis that the examiners are running that look at the institution's data compared to peers that meet certain criteria. In these specific cases the examiners were doing Redlining analysis and selecting institutions that had 25% or less high-priced loans in the assessment area and also had an origination rate between 50 – 200% of the comparator institution.
Using the Peer Group Builder described in the previous article, users can create a peer group matching the examiner's criteria, create a Fair Lending scorecard that compares the institution's percent of lending to substantial minority areas compared to specific peers and see if there are statistically significant variances. This is only one example of the power of the peer tools used in conjunction with Comply Fair Lending and the new Comply DataMine tool, but we thought it was important to illustrate that we can keep up with the changing regulatory scrutiny.
Here is a report in the process of being designed.
This is an example of a finished system template.
2018 HMDA Changes - What's the Word?
Comply 2018 HMDA Changes, Progress and Schedule
The implementation of the CFPB 2018 HMDA changes is now about a year and a half away. The new changes will more than double the number of reportable HMDA data fields that institutions must collect, edit and submit. In analyzing the new fields that were added to the HMDA requirement, we have identified 14 fields that presently exist within Comply and 39 fields that will need to be created. The new fields to be added are for automated underwriting, expanded race and ethnicity as well as general loan and property data points. Over the last month, we have designed the new application information screens in Comply and have grouped all of the fields appropriately.
The submission format for the 2016 data will be unchanged from the last few years. The 2017 submissions will contain the exact same data but they will be wanting to receive it in the new pipe-delimited format. We guess they are just wanting institutions to get used to using that format but we believe it will cause confusion. For the next three years' submissions institutions will use three different formats to submit the data!
- 2010-2016 Fixed-Length 380 byte record with revised format of Transmittal and LAR Records
- 2017 Pipe Delimited (TXT) records with same old data from 2016
- 2018 Pipe Delimited (TXT) records with new 2018 HMDA fields
As yet to be determined are the required edit changes for the 2018 reporting year. These edits will likely be substantial, given the new fields and the number of enumerated values for those fields, as well as the rules regarding the combining of the field values. We foresee a significant increase in the number of edits, both Quality and Validity, which will need to be incorporated upon release. As yet, there has been no public activity on the CFPB's part in regards to new edits.
The Universal Loan Identifier (ULI) has been a source of concern for many clients. Due to its requirement in the submission file we have come up with a solution that will help institutions standardize the ULI in Comply. RATA will be adding Legal Entity Number to Reporting Entity Properties in Comply. During an import, the process will automatically determine if an application number is already in the ULI format or not. If it is in the format it will break it down into its individual components. If the application number does not contain a ULI it will be automatically calculated in Comply. On the application screen Comply will show the application number separately and will also show a read-only field with the calculated ULI with Lender number including the check digit. So basically Comply will have the ability to use an existing ULI if available from your loan origination system(s), or in event you do not have one, it will be created for you.
This screen shows you the first tab of the new 2018 data entry screen including the ULI, LEI and Application Number.
We will be releasing a full install version of Comply 17 in January of 2017 that can be installed to a test environment (as we don't recommend updating to the new changes until after the 2016 submission). We will release the update version of Comply 17 for production systems after the 2016 submissions.
Many of the comments regarding the final changes expressed serious security concerns with the new fields being captured and submitted; the reporting of Age, Credit Score, Combined LTV and Debt-to-Income for example could be used for any number of improper purposes. Since the Comply software is housed within your infrastructure, the data will be secured using your facility's security measures, so there is no concern from the Comply perspective. From the perspective of the CFPB however, this is still an open issue. Many industry commenters have remarked on the need for enhanced security and redaction of certain data when disseminating it to the public. The CFPB simply states that they will take a balanced approach in determining what data to distribute and will make that determination at a later date.
Here are a couple more screen shots illustrating the next three tabs for your reference.
Please keep in mind that these screens are not 100% finalized and may change slightly at RATA's discretion.
Comply Audit and the Era of Application Versioning
We are excited to announce another new tool that will be of use to most of our users. It was one of the most requested features over the last couple years. Institutions wanted a way to track every change made by users and be able to see what changed and to roll back to a previous version.
The new Comply Audit tool is an optional Comply component designed to handle all aspects of Application Versioning. When this option is purchased and turned on, it will maintain copies of every application that is touched by any process in Comply and retain each version for review. If someone goes into an Application and changes the Action type from 1 to 6, it will make a copy of the application before the change and then the new version of the application. When you look at the history of an application you can see every version.
There will be an Audit dashboard that will show different ways to drill down into your auditing. You can see all changes by a specific user, a process, after a specific time frame and more. Once you drill down to the records in question you can roll back one at a time or in batches based on your current view. We will be demonstrating this new optional tool as well as the new Comply DataMine tool during our Customer Care reviews. Feel free to call for quick demo of these tools if you would like to see them sooner and to get our special client pricing for these new options. To show our appreciation for your loyalty we will be offering a two-for-one promotion to all current customers through the end of the year.
New CRA Performance Reports
Comply 16 will now incorporate the Examiner Audit tables as frequently created when bank examiners perform their onsite audits. The tables appear in most CRA Performance Evaluations and the Comply versions were created by combining the versions created by all agencies. There are a total of eight Examiner Audit Tables that have been added as shown below, and as with all reports in Comply, they can be run by geographic area in either combined or individual mode.
The Loan Distribution table is a simple consolidation of loan counts and dollar amounts with the percentage for all CRA and HMDA loans.
The Market Profile table gives the demographic details of the designated geographic area broken down by census tract income. The details include number of census tracts in the area as well as population, housing, family, household demographics and small business and small farm based upon the prior year's CRA submission of all lenders.
The Branch/ATM Distribution table shows the location of branches and ATMs within a designated geographic area broken down by census tract income. The table also shows the breakdown of family counts to aid in determining if Branch/ATM resources are sufficient to provide for the number of families.
The Loan-to-Deposit Ratio table displays the total loan amount and the deposits reported to the FDIC during the previous reporting cycle and the calculated Loan-to-Deposit ratio for your institution as well as any peers selected.
The Distribution of All Lending table shows lending to the designated geographic area broken down by census tract income in comparison to the aggregate lending data from the FFIEC CRA and HMDA submissions by all lenders.
The Distribution of HMDA Loan Data by Borrower Income table shows the distribution of HMDA applications within the designated geographic area, broken down by the borrower's income.
The Small Business Lending by Loan Value and Revenue table shows the lending in a designated geographic area broken down by loan value and revenue in comparison to the aggregate lending data based upon the prior year's CRA submission of all lenders.
The Small Farm Lending by Loan Value and Revenue table shows the lending in a designated geographic area broken down by loan value and revenue in comparison to the aggregate lending data based upon the prior year's CRA submission of all lenders.
The Loan Portfolio table gives a snapshot of the overall status of your CRA and HMDA lending, the deposit figures and related loan-to-deposit ratio as well as the census tract penetration for the designated geographic area.
Flexible Fixed-Length Exports
For those of you who are familiar with the export application data functionality you will be pleased to know that the fixed-length export capabilities have been expanded to provide you with even more options in exporting your data. It is our goal to provide our users with the most hassle-free compliance system in the industry and these data export changes are just one more way Comply will unshackle you from senseless data migration restrictions.
The following text will describe the changes that have been made to expand your exporting capabilities. You can implement these changes when creating or editing export definitions as they are now part of the export definition wizard.
The first change is on the "Format" tab of the wizard. The save as types have been changed to delimited or fixed-length. You can choose pre-set delimiters from our radio buttons (comma, tab, pipe, and semi-colon) or you can choose "other" and define your own delimiter. If you choose fixed-length you have the ability to further define options in the new "Fixed-Length Properties" tab (this will be expounded upon later in the article).
Another change that we have implemented is the option to define your row terminators. In the past the system was set to just allow the standard carriage return and line feed (CR/LF) row terminator, but now you can choose between line feed (LF) or "no row terminator" as well.
If you do choose the option of a row terminator other than CR/LF the system will prompt you with a warning of your selection choice. This is correct behavior as CR/LF's are the standard selection and a deviation may yield an undesired result. It is our goal to keep you aware throughout the export definition wizard process.
Just in case you need a reminder we provide a set of definitions to explain the save as types. While this may seem like common knowledge to some we realize that creating export definitions is not something that is typically done with frequency and this quick reference will help guide you in properly setting up the definition you require.
The most significant changes can be found on the new fixed-length properties tab. Previous versions of Comply had fixed-length export definitions with static properties that were specifically set based on the database schema. Now Comply will allow users to specify properties per export field; this will deliver a more robust and flexible fixed-length export.
All of the defined export fields will be listed in a box on the left-hand side of the tab. The export length has been included with the field name for quick reference. As each field is selected in the export field list the properties for that field (located on the right-hand side of the tab) will change to reflect the corresponding field settings.
The following property options now exist:
- Field Length – Sets the amount of space designated in the export file for the field.
- Justification – Justifies the data to the left or right side of the field.
- Padding Character – Pads out unused field space with a specific character.
- Date Format – If the field is a date you can choose from a list of standard date formats.
Overall we know these additions greatly improve the export flexibility of Comply and we encourage you to utilize these features to meet your needs and simplify data management between systems.
Advanced Mapping Features
The mapping feature in Comply has been evolving over the years with new features that sometimes get overlooked by our users. Some of our advanced features recently included have been the Select Data, Select Geography Toggle, and Snipping Tool.
It is common for Comply users to view their loans on a map. But sometimes filtering down to those loans in an area would also be helpful. Using the Select Data feature in Comply can now help you filter to those applications.
The Select Data feature allows the user to highlight an area either by using a rectangle or circle highlighter. Once the area has been selected, you can View, List or Explore the applications in that area. It will then filter your data to those applications that are within the highlighted area.
The 'View' option will display your applications in our normal single application view whereas the 'List' option will display in a list view. The 'Explore' option will allow you to filter your data down even further.
Geographic Data Toggle
Comply users know that one map does not fit all. Sometimes maps need to be viewed in various shading areas before committing to one. The Geographic Toggle tool allows you to view the map shading in multiply ways. Users can now create a map and change the shading from their assessment area to view the MSA\MD, County, Census Tract, City, ZIP Code or even Native Lands. If for some reason you need to include a tract after you created your map, you can now add an individual tract on the fly. This is done by clicking on Select Geography to display you select mode.
You can select Fully Contained which will only display tracts that are fully contained in your highlighted areas or Partially Contained which will display all tracts that are touching the highlighted area. Once you add the tract(s) it can be saved to your definition or a new definition can be created altogether.
Microsoft Snipping Tool is the latest addition of options we added to Comply Mapping. Sometimes saving out your map causes the quality of the map to be degraded. With the Snipping tool you can now make a copy of your map without losing the quality. It also gives you the ability to add your map to an existing report or document with ease.