Managing Risks To Data Integrity And Security

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Sanjeev-MalaneyToday’s lending environment is far different from that of even just a few years ago. Heightened regulations, increases in unannounced audits by the CFPB and an ever more-complex economic environment have forced originators to change the way they do business. But even with the myriad of changes that have taken place over the past several years, there’s one threat to lenders that has remained constant: the inability to maintain data integrity.

The mortgage industry has long struggled to ensure the quality, transparency and auditability of loan information. Lenders struggle with data entry errors, conflicting information that requires risky judgment calls and untold hours spent trying to complete and reconcile data after a loan is funded. As a result of the part “bad” data played in the recent financial crisis and recent litigation, quality initiatives are taking hold across the industry. Regulators are working to ensure that proper oversight is in place to authenticate loan information throughout the loan process.

Some common practices and beliefs contribute to a lender’s inability to ensure data integrity and security, including the reliance on paper-based processes, the mistaken belief that the LOS is the source of truth for loan data because it is the system of record and the use of insecure methods to share loan documents with others involved in the loan transaction.

Paper-based processes should be a thing of the past

While the printing, copying, and shipping of paper documents should be a thing of the past, for many lenders, it is still at the heart of the origination process and contributes to the inability to maintain data integrity. A typical loan captures thousands of pieces of data, and the potential for error is huge.

The reliance on paper also poses a huge security risk. Visit any lender with a paper-based process, and it is obvious that keeping confidential information secure is a losing battle. Paper files with confidential borrower information are stacked on desks and on tables in clear view of anyone who might be visiting the office. Account numbers, social security numbers and other personally identifiable information is in the clear, available to anyone who might have bad intentions.

Once the loan is funded, it is still very common for a lender to retain all paper loan files in a storage unit or warehouse, to be searched through manually whenever necessary. By doing this, however, they put the files and confidential borrower information at great risk. Anyone who has access to the files has access to a treasure trove of confidential borrower information. If the warehouse or storage facility is broken into or damaged by fire or inclement weather, there is no insurance policy that can keep the confidential information from criminals or that can replace the lost information. Third-party document storage services are often seen as good alternatives, but are expensive and often located far from the lender’s office, resulting in an inconvenient, inefficient, and costly search and retrieval process.

Moving to a paperless process improves data integrity and increases overall data security. Today’s imaging and document management solutions replace paper mortgage folders with electronic loan files that are processed electronically from beginning to end. Using a modern document imaging solution, lenders eliminate the manual entry of loan data which introduces inaccuracies, and lenders have a reliable online workflow that results in better protection for loan information, as well as higher productivity, reduced costs and higher quality loans.

In addition, paperless technology guarantees an easily accessible audit trail for a loan file, enabling lenders to collect information quickly and have all corresponding communications relevant to that loan available within seconds. In the case of an audit, rather than scrambling to gather paper files that may be difficult to locate, lenders have complete electronic loan files available to them with a couple mouse-clicks.

Your LOS is not the source of truth for loan data from documents

While relying on paper exposes vulnerabilities in and of itself, the central issue affecting data integrity is the potential for inaccuracies when data is entered, or overwritten, in a lender’s loan origination system (LOS). Many lenders mistakenly believe that an LOS is a “source of truth” for loan information. In fact, an LOS is primarily a “system of record”, capturing, storing and listing information, which can be mistyped or manually changed over the lifecycle of a loan.

While the best source of data associated with the loan is the original documents used in the loan process, LOSs don’t provide the lender with the appropriate tools to easily locate the data on the original document and compare it with what is in the LOS.

Today, lenders invest a lot of time and resources playing the “stare and compare” game, in which a human being compares information across multiple loan documents to spot discrepancies, and also compares the information on the source documents to the information in the LOS. Whether the lender uses in-house staff or outsourced labor to complete the task, this practice is time-consuming, error-prone and costly. In most cases, this quality control (QC) is done late in the process, or even after the loan has closed, limiting any possible corrective actions. With more comprehensive document management technology, lenders are able to implement QC throughout the lifecycle of a loan, not just at the end, which leads to better quality loans and better business decisions.

An advanced document imaging and collaboration platform also provides the ability to extract data from loan documents and to validate that data across any number of loan documents, while always maintaining a link to the original source document. This technology makes it easy to compare data in the LOS with the data on the original document and alerts the lender of discrepancies in the data, as well as missing data or missing documents immediately.

Maintaining the link to the source document is critical. An LOS system can extract data for rules engines and other purposes but loses the connection between that data and its source document. If multiple versions of the same document are submitted for a loan, which version of the document served as the source for the data value that is in the LOS? With best-of-breed document management technology, the lender is always able to link from the data to an electronic image of the source document, so the source can be verified and is never in question.

What’s more, a comprehensive audit trail is created for any changes made to the data values, while always maintaining a link to the source documents. An LOS creates an audit trail of changes made in the system, but, again, the link to the original document is lost.   If a regulator were to request an audit, lenders should have the confidence that the tools they use to run their businesses will help see them through an investigation rather than send them to a warehouse to sift through stacks and stacks of yellowing documents and possibly never find the source document required to validate a business decision.

Sharing Isn’t Always Good

During the life of a loan, many parties are involved in the transaction including lender representatives, real estate professionals, title insurance agents, closing officers, and many others. Moreover, each of these parties is accustomed to different workflows, technologies and protocols when handling loan files. Today, much of the communication between these parties is done via fax, email, or the transport of paper files back and forth. The insecure channels used by the parties to collaborate on loans not only introduce the risk of human error, but significantly increases the security risk of lost or stolen files.

A document management platform gives lenders the ability to securely collaborate with co-workers and third-party service providers as the loan moves through the process. An LOS system may provide collaboration capabilities, but not secure “workspaces” where lenders can invite co-workers, or trusted service providers, to exchange documents and collaborate through the loan process. Using a document management platform for secure collaboration also speeds the transaction because electronic communication is instantaneous, and days aren’t wasted resending lost or poorly transmitted faxes or mailing paper documents back and forth. Emailing faxing, and shipping documents that contain sensitive information in the clear should be a thing of the past, and a best-of-breed document management platform offers a secure, more efficient alternative.

The mortgage industry has seen more changes in the past several years than in the past few decades. As a result of these changes, lenders must be prepared to change the way they do business by investing in technology that ensures loan data integrity and security.

By using a software solution designed to ensure data integrity, lenders improve the consistency and quality of loan information throughout the lifecycle of the loan, not just after a loan closes, when it is often too late to remedy. Technology also increases the security of loan information, as it replaces paper-based processes with secure, electronic channels for document management and collaboration. In today’s increasingly competitive and complex lending environment, the focus should be on delivering high-quality loans. With a focus on data integrity and security, lenders will be better able to meet both their operational objectives and financial goals.

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