HMDA

Quarterly Submission

RiskExec has been updated to support clients who are now required to file their 2020 HMDA LAR on a quarterly basis.  When a user clicks “Submit LAR” within the HMDA module and begins the process of creating submission files, the user will now have the option to create an Annual, 1st Quarter, 2nd Quarter, 3rd Quarter, 1st and 2nd Quarter, or 1st, 2nd, and 3rd Quarter submission file. 

Under the current guidance of the CFPB, when a user files 2nd Quarter data they will have to decide whether to submit the 2nd Quarter only or a combined 1st Quarter and 2nd Quarter dataset.  Then RiskExec will internally use an Action Date filter to appropriately select the records based on the option selected above.

As of today, the CFPB submission portal is not ready for testing quarterly files, hence the RiskExec team does not have any way to confirm the validity of such files.  As soon as the CFPB makes the site available, RiskExec will work with our clients to verify quarterly files if requested. Please note, verification by a RiskExec team member of a submission file is not required prior to submission.  

Additionally, RiskExec has updated its Export options to allow users to export quarterly HMDA submission files. The logic for these exports mirrors the logic used in the submission files discussed above. 

For more regulatory information on quarterly HMDA submissions, please refer to the CFPB’s Supplemental Guide for Quarterly Files.  

HMDA Application Detail

RiskExec has made updates to the HMDA Application Detail page which allows a user to select NA or Exempt (for files marked exempt) as a value in the dropdown option for those fields where NA or Exempt is a valid value for submission.

Filters

RiskExec has added a new filter capability that will allow users to compare two numeric or two date fields.

Maps

Themes

RiskExec has added a new theme called the Tract Distressed/Underserved theme.  This theme highlights distressed or underserved nonmetropolitan middle-income geographies designated by the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency.  This theme is based on:

• Rates of poverty, unemployment, and population loss
• Population size, density, and dispersion. Activities revitalize and stabilize geographies designated based on population size, density, and dispersion if they help to meet essential community needs, including needs of low- and moderate-income individuals.

County Label

When a user applies the County Layer on a map, the word “County” has now been removed in an effort to show more county labels on a map.

Assessment Areas

Assessment Set Types

RiskExec now provides the option to create three types of Assessment Areas: 

• Submission assessment areas (default) must consist only of whole geographies and should consist generally of one or more MSA(s) or one or more contiguous political subdivisions, such as counties, cities, or towns, in which the bank has its main office, branches, or deposit-taking ATMs.  Duplication of tracts across assessment areas within a submission set is not allowed. These sets can be associated with your HMDA or CRA files and can be used to do analytics on HMDA or CRA data.

• REMA (Reasonably Expected Market Areas) are used to evaluate redlining risk, must consist only of whole geographies, and are intended to define where the institution could reasonably be expected to market and provide credit.

• Geographic assessment areas have no restrictions on the geographies selected, can contain overlapping tracts, and are intended to be used for specialized reporting purposes.

Zip Codes

Geographic assessment areas using 2019 and greater census data can now use zip codes as units.  Please note, because demographic data is only available at the tract level, the zip code units are built at the tract level, using the HUD Crosswalk File.  If a tract is listed in the Crosswalk File as having any part of it within the selected zip code, then the entire tract will be included in the assessment area unit.  This means that the zip code units will often have a larger population than the comparable Census ZCTA.

Exports

RiskExec has added three additional export options: 

• The RiskExec Modified LAR Export:  This is an export that matches the format specified in the CFPB 2018 and later Modified LAR scheme published at https://ffiec.cfpb.gov/documentation/2018/modified-lar-schema/.  This export can be used to send LARs to those requesting a copy of a sanitized modified LAR.

• The RiskExec FFIEC Geocoding Export:  This is a comparison of all file records compared to the FFIEC Geocoder’s results. It lists the record identified, current RiskExec address, current RiskExec geocode, date the FFIEC was checked, the FFIEC return address and the FFIEC return geocode.  If the FFIEC portion of the report is blank it indicates that the FFIEC geocoding website could not give a geocode for that address that was provided in the file.

• The Soft Geocoding Export: This export will take records that do not meet RiskExec’s internal regulatory geocoding standards and were noted as “NOT GEOCODED” in the original geocoded results.  The export will show a user the “best” geocoded information that RiskExec did receive and will allow the user to manually review the Soft Geocodes to see if they would like to use them moving forward.  Click here to view RiskExec’s article on how to use Soft Geocoding.  

Reports

In addition to All Loan Purpose, Home Purchase, Home Improvement, and Refinance, RiskExec has added “Other” as an option for the HMDA Compliance - Disparity Indices report.

Miscellaneous

Due to the feedback from our clients on the redesign of the RiskExec platform, RiskExec has updated its font to improve overall visibility and readability.