Combat The Regulators With Data

How do lenders defend themselves against regulators? How do lenders prove that they are in the right? They embrace data. In fact, proactive vendors like ComplianceEase are making this easier and easier. ComplianceEase is revamping its RegulatorConnect Certification Program, called RC Certify, to help technology providers and lenders prepare for the more data-intensive mortgage examinations that have emerged over the past few years and are expected to soon include TILA-RESPA Integrated Disclosure (TRID) reviews.

Introduced in 2010, the RC Certify Program helps mortgage technology companies provide Lending Examination Format (LEF) files to their lender customers. For the past six years, federal and state regulators have required lenders to submit files in LEF format, using the RegulatorConnect Portal.

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Recently, the Multi-State Mortgage Committee (MMC) of the Conference of State Bank Supervisors (CSBS) noted in an industry bulletin that “despite years of preparation and anticipated compliance, the mortgage industry has regularly failed to provide clean data in a format acceptable to the regulators’ technology platform.”

The bulletin warned: “The MMC will continue to rely heavily on this technology and will consider companies that cannot provide data that is complete, accurate, and properly formatted to be non-compliant with respect to records production.”

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In response to these concerns, ComplianceEase, which developed the LEF format and the RegulatorConnect Portal, is redesigning the RC Certify Program to create an easier, more standardized path for technology providers to update their systems to export loans in the latest LEF format.

The new process will help industry software developers at each step in the design, development, integration, and testing of LEF file exports, the company said. With dedicated personnel working on the export, ComplianceEase estimates that technology providers will be able to complete the certification process in two months or less.

“For the past three years, our industry has been focused almost exclusively on redesigning technology to accommodate new mortgage rules: first qualified mortgages, and more recently TRID,” said Jason Roth, CMT, chief technology officer at ComplianceEase. “As a consequence, LEF requirements and integrations have moved down the queue at many tech companies, which is now creating new compliance issues for lenders.

“Although regulators have indicated that they will adopt an informal ‘grace period’ and look for ‘good faith’ efforts to comply with TRID, we expect that examiners will soon be reviewing for compliance with TRID requirements, and will expect electronic data to be readily available for these more data-intensive exams. Our revamped RC Certify Program is designed to get ahead of this issue and to make file exports as easy as one click for lenders.”

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