RiskExec is a comprehensive web-based compliance reporting and analysis platform that automates HMDA, CRA, redlining, and fair lending processes.

The downloaded 2020 HMDA data includes 4,400 institutions comprising over 25 million records.

“RiskExec learned that on March 31st, the CFPB began loading the 2020 HMDA data onto their files platform. We prioritized getting the data to every RiskExec client, and are pleased to report that the morning of April 1st,  all RiskExec clients gained access to the released data,” says Andy Sandler, Founder and CEO, Asurity. “Being first to market is a continued capability we pride ourselves in and we are committed to providing the best service and support to our clients.”

“Last year 2020 was a banner year for residential lending and the current administration has greatly expanded its focus on the use of this Peer data for Fair Lending and Redlining reviews. It is vital for our clients to quickly and easily understand how their lending profiles compare among peers,” says Dr. Anurag Agarwal, Founder, President and Chief Architect of RiskExec. “RiskExec will be updated weekly as this data changes due to resubmissions resulting in a final aggregate data release by the CFPB later in the year.”

From goal setting, dedicated redlining analysis, and interactive mapping to peer rankings and data visualization, RiskExec provides executive and regulatory reporting for the Home Mortgage Disclosure Act (HMDA), Community Reinvestment Act (CRA), and fair lending compliance requirements.

In this new role, Julia will be responsible for overseeing and managing the development, launch, and commercial deployment of AMG software products, including a new state of the art mortgage loan document solution, launching in the coming months.

“Asurity has exciting times ahead, where the key to our growth will be the successful launch of new products and continued innovation, paired with exceptional client support and onboarding,” says Luke Wimer, Chief Operating Officer, Asurity. “The addition of Julia to our leadership team couldn’t be more timely, and her expertise will accelerate our efforts to push the market forward.”

During her more than 25 years in professional services and software products, Julia has demonstrated success in growing and managing businesses at the intersection of legal, software, and outsourcing. Most recently, her efforts helped to transform and deploy a records management software solution used by large and complex global enterprises to manage physical and digital assets.

Julia’s leadership capabilities extend beyond commercial products and solutions. She currently serves as an elected board member of AIIM International, whose mission is to improve organizational performance by empowering a community of leaders committed to information-driven innovation. AIIM is a member-based association with year-round activities and resources. Julia also has volunteered as a mentor for the Executive Women’s Forum (EWF) in order to engage, develop, and advance women leaders in information security, IT risk management, and privacy. Julia will be based at Asurity’s Washington, D.C., headquarters.

HMDA and CRA

Select File

Users now have the ability to search for a specific file name using the search bar on the Select File screen. To clear a search, click on the X at the end of the search bar.

File Comparison Report

The File Comparison report now includes total columns for the number of loans and amounts. These new columns provide an aggregate total for the comparators chosen. 

Edit Checks

There is a new Enhanced Quality Edit Check, G028, in the HMDA and CRA modules that will be triggered if a city name contains any characters other than alphabetic characters, spaces, or periods. For example, if there is a “-” in the city field, this edit check will be triggered.  This is an Enhanced Quality check and only serves as a marker to find issues in the City name. It’s not assured to be correct for every city.

There is a new Enhanced Quality Edit Check, G029, in HMDA that will be triggered if the MSA is invalid.

There are two new Enhanced Quality Edit Checks, G026 and G027, related to Community Development Loans in CRA:

G026 - CD Loan Amount in CD Details tab does not match the CRA Submission Loan Amount in the Information tab.

• There are two amount fields available to a Loan Type CD in RiskExec, one is Loan Amount ($000s) on the Information tab which is used for submission aggregation purposes and the other is CD Total Amount on the Community Development tab, which is an optional field and can be input as the exact dollar, left blank, or entered in thousands based on how and if the client uses the field in any reporting or for reference when on the Community Development tab.  This quality check is triggered when there are differences in these two numbers fields for informational purposes if you want the fields to match.  The critical field for submission purposes is Loan Amount ($000s) on the Information tab.

G027 -  CD Loan amount is 0

• For Loan Type CD in a CRA file to be appropriately aggregated for total # of CD $s for a submission file, the CD loan qualified amount must be populated in Loan Amount ($000) on the Information tab.  This quality check is triggered if that field equals zero. 

Edit Checks and Geocoding

If the Edit Checks and Geocoding are not current on a file, a red symbol will now appear on the Edit Check Detail and Edit Check Summary screens. If you hover over the symbol, a message will indicate whether edit checks, geocoding, or both are not current.

Import Report

The Import Report has been updated to include specific color codes that will highlight when an error has occurred to help draw your attention to the information that’s most important identifying problems and successfully importing your data.  An item highlighted in red indicates a failure or critical error and an item highlighted in yellow indicates a warning.

Filtered Export

If a filter has been applied to an export from HMDA or CRA, this will now be indicated by a filter icon. If a user hovers over the filter icon, the parameters of the filter will be displayed. In this example, the filter applied to this export was Loan Type = Conventional and Loan Purpose = Home Purchase.

Miscellaneous

RiskExec has been updated with the most current 2021 Dun and Bradstreet Small Business/Small Farm counts data. 

The Memorandum is addressed to the Secretary of HUD, with the request to examine the effects of two rules related to fair housing that were enacted during the previous Administration, with an eye towards rescinding them in the near future.  As of this writing, the President’s nominee is still in the Senate confirmation process, so presumably the Memorandum is directed to the Acting Secretary of HUD.

As background, in 2020 under the prior Administration, HUD issued two controversial rules under the Fair Housing Act.  The first rule repealed the “affirmatively furthering fair housing,” or “AFFH Rule,” which required governmental entities receiving federal housing funds to examine patterns of housing discrimination in their jurisdictions and work to curtail them.  The second rule from the previous Administration amended standards under the Fair Housing Act for determination of disparate impact (the “Disparate Impact Rule”).  This second rule has been stayed by preliminary injunctions in several suits challenging its compliance with the federal Administrative Procedure Act.

The Memorandum directs the Secretary to examine the effects of the AFFH Rule and Disparate Impact Rule in light of HUD’s statutory duty to enforce the Fair Housing Act.  Based on the results of that examination, the Memorandum further direct the Secretary to “take any necessary steps'' to implement requirements for HUD to administer the Fair Housing Act “in a manner that affirmatively furthers fair housing and HUD’s overall duty to administer the [Fair Housing Act,] including by preventing practices with an unjustified discriminatory effect.”

Stay tuned for future regulatory action that will certainly come from HUD after it acts on this Memorandum.

Due to the quality and extent of innovation in these sectors, HousingWire has noted the increasing level of competition for gaining this highly sought-after recognition: “After the uncertainty and unpredictability of last year, we expected a greater adoption of technology. However, these 100 real estate and mortgage companies took digital disruption to a whole new level and propelled a complete digital revolution, leaving a digital legacy that will impact borrowers, clients and companies for years to come,” said Brena Nath, HousingWire’s HW+ Managing Editor.

“At Asurity, we are honored to be selected as a recipient of HousingWire’s Tech100 award for the fourth consecutive year,” said Andy Sandler, CEO, Asurity. “In 2020, our team faced unprecedented challenges and rapidly adapted, continuing the development of innovative solutions while maintaining quality service levels for our valued clients. We are energized by the challenge of continuing to build cutting-edge software products that fuse exceptional compliance standards with state-of-the-art features designed to drive efficiencies and enable business outcomes.”

Asurity delivers compliance-driven products and solutions tailored for the mortgage lending market, serving over 200 clients including half of the nation’s top 25 mortgage lenders. Asurity’s product suite includes RiskExec, providing data analytics and regulatory reporting capabilities to help lenders manage their fair servicing, fair lending, HMDA, and CRA performance and related regulatory compliance obligations; AsurityDocs, delivering compliant mortgage document packages for home purchase loans, home equity lines of credit, and loan servicing tailored to satisfy regulatory requirements across all 50 states; and, recently launched, RegCheck, a loan compliance software tool with API, dashboard, and interactive UI capabilities.

Read HousingWire’s summary of the announcement here.

RiskExec’s innovative and rapid response during this unprecedented year brought clarity to complex challenges and put powerful tools in the hands of the industry’s biggest players as they navigated change.

Over the course of the year, RiskExec platform users expanded by over 30%. The nearly 800 active users represent:

• 6 banks with over $100B in assets
• Two new top 10 mortgage lenders by volume
• We now serve 40% of the top 50 lenders

In 2020, RiskExec processed 40% of the nationwide HMDA loan application records in its HMDA/CRA module, providing executive and regulatory reporting for the Home Mortgage Disclosure Act (HMDA), Community Reinvestment Act (CRA), and fair lending compliance requirements.

RiskExec launched the industry’s first dedicated Fair Servicing module in August. Loan servicing practices are becoming ever more critical in the world of COVID-19 loan forbearance and modification. To aid lenders and loan servicers in navigating these challenges, RiskExec’s cutting-edge Fair Servicing compliance module is specially configured to help lenders and servicers manage complex loan forbearances and modifications authorized under the 2020 Coronavirus Aid, Relief, and Economic Security (CARES) Act.

In September, RiskExec announced the successful integration of the Payment Protection Program (PPP) Loan Level Data from the Treasury Department and the SBA into its RiskExec platform Peer Analysis module. RiskExec customers are now able to construct Peer PPP Groups based on geographies and analyze their own data against peers. This opportunity to compare impact with peer institutions is especially important as regulators have indicated they will soon start examining how lenders handled PPP funds.

“RiskExec's solutions led the field in 2020, but compliance was always just the beginning," said Luke Wimer, Chief Operating Officer at Asurity, "bringing unparalleled value to clients and the industry, staying responsive to changing needs in real-time ensures our clients succeed in advancing equality across communities they serve.”

1. Verify your credentials with the CFPB now:  Log into the CPFB HMDA Submission Platform as soon as possible using the credentials you should have received when your institution obtained an LEI and first submitted HMDA.  This ensures that you will not have any future issues logging in when you are ready for your submission.  If this is your first time, then please use the link here to obtain your credentials: https://ffiec.cfpb.gov/filing/
2. Review your Transmittal Sheet ASAP:  Review and confirm that all information contained in your Transmittal Sheet is correct in both RiskExec and on the CFPB's website.  We especially recommend this for institutions that may have recently gone through a merger or acquisition as your Transmittal Sheet information may have changed.  You don’t want to try and submit incorrect information!  For those institutions submitting multiple LARs, please make sure all of your LEIs are available in the CFPB portal and all of your RiskExec files contain the proper LEI and Agency code for each LAR.
3. Keep Edit Checks and Geocoding Current:  When you load a file in RiskExec, we provide the status of the Edit Checks and Geocoding on the File Summary tab.  It will indicate when an institution’s Edit Checks and Geocoding are “not current.” A file may lose its “current” status if there is prolonged inactivity in the file, or if there has been a change made to your data (i.e. changing fields on a loan or importing a new file).  Both statuses must be current before a client requests verification from the RiskExec team.

Redlining

RiskExec has updated its Redlining module to include Payment Protection Plan (PPP) loan data as a new Data Type.  In addition to existing HMDA and CRA options, now when a user creates a Redlining dataset, they are given the option to choose PPP as a Data Type to be analyzed. If the user selects PPP as their Data Type, they are then given the option to choose data that was directly uploaded to the Redlining module, data from the CRA (for most cases the institution should be keeping the PPP data in a RiskExec CRA file) module, or they can choose to merge existing PPP datasets in the module to create a new dataset to be analyzed.

In order to include public peer data as a factor in a Redlining analysis, the user must first set up a PPP Respondent Group in the Peer Analysis module and select the institutions that they would like to include.

The user may then select that PPP group in the Redlining analysis setup.

NOTE:  The RiskExec geocoding results on the public PPP data was subject to the quality of the address data provided on the SBA application, i.e. P.O. Box or other non-physical address information being used. Due to this, the RiskExec PPP peer data may vary from an institution’s internal PPP data set where a full physical address may have been available for geocoding.  For this reason, it is recommended that institutions use a three-line comparison for internal reporting of PPP performance and peer comparison:

• PPP Peer Aggregate Data
• PPP Peer Institution Data
• PPP Actual Institution Data

Redlining Results Summary

The Redlining Results Summary tab has been organized so that the geographies that contain the most factors with a “May require further review” are ordered by the total.  Additionally, there is a new column titled “Review Count” that indicates the number of factors in the analysis that may require further review for a given geography.

Assessment Areas

Users are now able to create an Assessment Area with the radius tool’s Tract Demographics Report and add it to an existing Assessment Area Set using any map in RiskExec.

To do so, a user can click on the radius tool and draw their desired radius.

A user can then open the Tract Demographics report and select the tracts they want to include in their new Assessment Area.

Select the Assessment Area Set you want your new area added to and give the area a name. Clicking "Create Area" will add this new Assessment Area to the selected Assessment Area Set.

Manage Institution

The User-Defined Fields and User-Defined Codes sections of the Manage Institution tab are now organized into tabs for easier navigation.

Batch Geocoding

Users can now control who has access to files in the Batch Geocoding module. A user with Administrator access to a file can adjust permissions for that file using the "File Access" option in the side menu.

Miscellaneous

We have upgraded the engine that performs our Dynamic Import process to automatically resolve some common problems in data files, give better feedback to the user about problems with the data that may prevent a successful import, and provide better performance when importing large data files.

In preparation for this year’s HMDA submission, RiskExec recommends that you verify the Rate Spreads on all of your records and confirm that they are correct.

In 2020, there were two instances where the CFPB had an error in the APOR tables on their website. It is important to note that these tables are used to calculate the Rate Spread in your RiskExec HMDA records.  However, the RiskExec system will only maintain the most current set of APOR tables and will automatically update the tables if and when the APOR tables are updated on the CFPB website. 

The RiskExec team has connected with the CFPB on several occasions in an effort to receive guidance on how to handle this situation.  Unfortunately, the CFPB has not offered any clear recommendations on which rates to use for loans that were locked in during the period when the APOR tables were in error.  Therefore, RiskExec recommends that each institution review all of the loans that were locked in or booked on the dates in the ranges listed below. Please evaluate all Rate Spreads in preparation for your institution’s submission.

The first incident occurred during the release of the tables on July 17, 2020, for the APOR Rates for Fixed Rate Loans.  Please see below:

The RFI requests industry comment on methods to modernize the appraisal process, the uniform appraisal dataset (UAD) and appraisal design form, the use of automated valuation models (AVMs), and valuation differences by borrower and neighborhood ethnic makeup. The RFI us available here.

The stated goal of the RFI is to ensure that GSE appraisal policies not lead to competitive practices that could erode GSE safety and soundness.  Specifically, FHFA is looking for activities that may be used to manipulate automated underwriting system results or result in the adverse selection of a GSE with less stringent appraisal requirements.

One suggestion for appraisal modernization in the RFI called a ‘hybrid appraisal,’ in which an appraiser, home inspector, or even a realtor visits the property and collects data for one of the GSE’s automated underwriting system and collateral tool (Freddie Mac’s Loan Collateral Advisor and Fannie Mae’s Collateral Underwriter).  If warranted, the automated underwriting system will also require a desktop appraisal from a licensed appraiser using the data already collected.

A second suggested step is to redesign and update the UAD and appraisal form to align with the current MISMO version, add recommended new data points and delete unnecessary ones, and update the form to have the same look and feel of the new GSE loan application and federal Loan Estimate and Closing Disclosure.  This portion of the RFI has been in process for some years, and is ongoing.

The RFI also requests input on policy updates to allow appraisal waivers on GSE-eligible loans, and potential methods to address concerns about undervaluation of residential property in minority communities.

Comments are due to FHFA on or before February 26, 2021.