Market Analysis: Getting Ready For ULDD

*Getting Ready For ULDD*
**By Tony Garritano**

***The Uniform Loan Delivery Dataset is a major change in the way the mortgage industry not only delivers loans between lenders and investors, but is also a significant development in how loan data is verified, analyzed and evaluated. By having the individual data elements of each loan available in a standardized digital format to compare and study, investors can more easily review files to ensure greater data integrity in each loan. Analysis and reporting are greatly improved, bringing much-needed transparency and quality to the capital markets, leading to greater liquidity and reduced costs for all stakeholders in the process. Initially applying to loan deliveries involving Fannie Mae and Freddie Mac, the ULDD effectively sets the stage to become the new industry standard upon implementation. And PROGRESS in Lending has learned that one LOS is already compliant. Here’s the story:

****Mortgage Builder has already received certification from the GSEs that it is in compliance with the new Uniform Loan Delivery Dataset (ULDD) requirements, well ahead of the April voluntary loan delivery date and the July 23rd mandatory delivery deadline. The agencies pushed back the mandatory date from March to July to allow vendors and lenders more time to prepare for the change, but Mortgage Builder clients can familiarize themselves with the changes immediately.

****By being early with its readiness for the ULDD, Mortgage Builder allows its clients greater preparation time to meet the requirements of the new system and its differences. “There are many new data fields and it will take clients some time to become acclimated,” according to Liz Fafette, Mortgage Builder’s vice president of operations. “We have made every effort to make the transition as seamless as possible for users by giving them an advance view of the changes as far back as November, so that helped,” she explains. “The upload websites for Fannie and Freddie are different, but we have worked hard to make the user experience as consistent as possible with the current Mortgage Builder environment.” She notes that more than 600 data fields were involved in the conversion to ULDD, and the newest version of MISMO-standardized XML (Extensible Markup Language, standardized by the Mortgage Industry Standards and Maintenance Organization) made the effort a significant undertaking.

****“ULDD brings greater standardization to the process for each transaction,” observes Keven Smith, president and CEO of Mortgage Builder. “ULDD brings improvements to the existing methods of electronic delivery that we anticipate will reduce issues around completeness and acceptability,” he says. “There is a checking feature that warns of possible problems or conflicts with Freddie or Fannie, and prompts users to fix them before uploading. This saves the GSE and the lender time, and the overall precision of the ULDD package will help boost transparency,” Smith predicts.

****Mortgage Builder was required to demonstrate that its system’s ULDD met the requirements and quality standards for the GSEs through a series of test cases with each agency. Now, with that process complete and Mortgage Builder duly certified, the company is releasing the new version for client download and implementation. “Our technical support staff is available to assist wherever required,” says Liz Fafette, but she feels that the effort put in by her operations department will make the transition remarkably painless. “With the implementation of ULDD by Freddie Mac and Fannie Mae, the mortgage industry is officially in the digital age,” she says. “We’re glad to help in the effort to bring new levels of data integrity and transparency to the mortgage industry, and Mortgage Builder is ready to go – months ahead of the deadline.”

Market Analysis: It’s All About ROI

*It’s All About ROI*
**By Tony Garritano**

***Why do technology vendors and service providers integrate? There’s a variety of reasons, but the biggest one is to provide their customers with more efficiency and cost savings. For example, PROGRESS in Lending has learned that LendingQB and FirstClose Title have a partnership that combines instant ‘cash to close’ quotes with real-time automated underwriting and loan pricing all within a unified loan origination platform. The integration enables mortgage lenders to reduce closing costs for borrowers and simulatenously populate guaranteed GFE data within the LendingQB loan origination system. Here’s the story:

****FirstClose Title is a national provider of title services with a unique business model. They compare rates from a wide range of major underwriters and provide the lowest price to borrowers and lenders in a transparent manner. “We actively seek out best pricing among major underwriters to deliver pure, unaltered comparative rate quotes,” said Cynthia Waterman, president and CEO of FirstClose Title. “This allows us to present quotes which average $500 to $1000 below competing GFE quotes, providing lenders with a ‘cash to close’ advantage that makes their offer more competitive and secures a relationship with a potential borrower more quickly.”

****The integration between LendingQB and FirstClose Title makes it easy for lenders to generate a GFE quote directly within the LendingQB loan origination system. Lenders can quickly retrieve quotes for title insurance, settlement charges, recording charges, and transfer taxes and automatically populate the data to the GFE on their loan file. Lenders can save between 15 and 30 minutes per loan file using the integration. But more importantly, FirstClose Title guarantees the accuracy of the GFE data, which protects lenders from having to cover costs due to poor GFE data entry.

****“As a loan origination system, our goals are to increase a lender’s efficiency and maintain data integrity,” said Binh Dang, LendingQB’s managing partner. “The integration with FirstClose actually goes beyond these goals and has a direct impact on a lender’s ability to drive revenue. It makes lenders more competitive by improving point of sale pricing and increasing consumer selection.”

Technology Spotlight: Lender Looks To Clean Up Its Approach

*Lender Looks To Clean Up Its Approach*
**First National Bank of Pennsylvania Profiled**

***In an effort to get rid of several front end and back end systems, PA-based First National Bank of Pennsylvania has opted to switch its LOS to Avista Solutions. First National Bank, the largest subsidiary of F.N.B. Corporation (NYSE: FNB), recently launched the Avista Agile LOS retail platform. Here’s why they chose Avista:

****First National Bank previously managed its mortgage lending operations from two separate front-end and back-end systems, which led to a less than optimum workflow process. The bank launched a search for a new system that could offer full transparency of information and in turn increase efficiency and data accuracy. After whittling its candidates down to four, the bank chose Avista Solutions as its best fit.

****It wasn’t just transparency that tipped the scales in Avista’s favor – the system’s web-based, software as a service (SaaS) model was also a deciding factor for First National Bank. Avista’s web-based format allows loan originators to easily take work into the field and keeps the bank from having to tap into its own internal servers for hosting purposes.

****DataMart, Avista’s onsite data storage and reporting tool, was another feature that won over First National Bank. The bank wanted the ability to produce a variety of reports that could be moved onto its servers quickly, and Avista’s DataMart stood out among competing reporting tools. Additionally, Avista’s data mining capability was important because of its potential to enhance cross-sell opportunities.

****Avista also offered a flexible implementation process that impressed First National Bank decision makers.

****“We chose Avista because the system has an infrastructure that can accommodate our growth,” First National Bank of Pennsylvania Senior Vice President and Real Estate Services Manager Rhoan Hernandez said. “Also, we can streamline and create an efficient, virtually paperless credit process. Not only is this environmentally friendly, but it will also ultimately improve the level of service we offer our customers.”


Our POINT Of View: Beyond The Buzz

*Beyond The Buzz*
**By Ted Hicks**

***Our industry loves buzzwords. But those buzzwords have created a lot of confusion in the market concerning technology as definitions vary greatly. Two of today’s most common buzzwords are “web-based” and “end-to-end”.  When we consult with lenders, we find that sometimes think that they want one thing but their actual need speaks to a different option.

****We hear a lot about the need to be “web based.” What does that really mean? Our lenders typically ask for web-based technology to have anytime, anywhere access and easier deployment without the need for resource-intensive applications.   But what they don’t realize is what they are asking for is already available—through the use of their current client-server model or even mobile applications.

****The term client server is lumped in with terms like antiquated and rigid. That’s just not the case. The client-server model has become flexible enough that client server can now be deployed over the Web as an ASP.   Client servers can enable off-line activity and automatic uploads of off-line files to the server upon the next login.

****Mobile applications, although not widely accepted or used in the mortgage industry right now, provide global 24hour access without unwieldy installations.  Mobile applications are, in essence, client server applications, not web applications viewable on a mobile screen.  These “mobile servers” are designed to keep us plugged in wherever we are without the performance, control and security issues that they can sometimes experience with a true web-based system.

****Our second buzzword du jour, “end-to-end” has also created a stir among our clients.  Let’s talk a bit about what end-to-end really means. End-to-end is different as compared to all-in-one. When you are talking end-to-end you need to define the starting point and the stopping point. You can be end-to-end when it comes to processing only, for example, or you can stipulate the starting point as the 1003 and the stopping point as the 1st payment after closing.  “All-in-one” is a complete package that includes all forms, documents, services, and servicing.

****That means a system where just one vendor provides every single one of the services for which you would normally use best-of-breed third-party vendors.  Look at it this way:  you would typically expect an LOS to offer expertise in mortgage origination software.  If you see one that also claims to be a document services company or a flood certification company, what is the likelihood that it is going to be able to provide excellence in all business models at the same time? More often than not, quality will suffer in one or more of the “businesses.”  If you find a system touted as “all-in-one” and look closely at its capabilities and functionality, you’ll find that they just don’t have what it takes to be “all-in-one.”

****What does all this really mean to you?  It means that there are options for you.  Rather than immediately jumping on the buzzword bandwagon, truly analyze your functional needs in a platform.  You may find that you already have what you want and need.   But you won’t know until you move beyond the buzz and get to the facts.

Powering Today’s Lenders: Tracking The Real Needs Of Lenders

*Tracking The Real Needs Of Lenders*
**By Daniel Liggett**

***This week, our ‘Lender Spotlight’ is on the Savings Institute Bank & Trust Company (SIBT) of Willimantic, CT. This is the second installment in our series where we share stories from actual lenders about how they selected and implemented technology initiatives. When the $950 million SIBT began their search for new loan origination technology, they set out to create a list of the capabilities that were essential in meeting their future lending requirements. One was to have the LOS and the accompanying data reside on servers within the bank’s existing internal IT infrastructure. The second was to process both mortgage and consumer loans from a single system. The remaining requirements on the list were derived from experiences with past systems. These included flexibility, customization, and vendor integrity.

****SIBT’s year-long search culminated in the selection of PowerLender, a business-rules-based LOS, with Specialized Data Systems (SDS) of East Haven, CT. providing the implementation and configuration services. SDS and SIBT designed an implementation plan and refined PowerLender to meet the bank’s specific way of doing business.

****We understood our workflow requirements. We have a mix including Conventional, FHA, 203K, Connecticut Housing products, EquityBuilder products and Rural Development products. Our operation is like many banks in the region and SDS had a firm grasp of our business and helped us implement it into PowerLender in a rapid fashion. It didn’t take long for us to discover that with PowerLender, anything we needed we could do.

****The project began in January and we went live with PowerLender in June. PowerLender helped streamline our workflow by providing third-party integrations with Desktop Underwriter, mortgage insurance providers and credit bureaus. The ability to attach documentation to a loan record reduced the resources we devoted to compiling and tracking these items.

****Our point-of-sale operations include both face-to-face and online using LoanQuoter by DataVision. Our plan is to take advantage of PowerLender’s web services which allow seamless, automatic transfer of loan data between the consumer-facing portal and the LOS. Thus data entered by the consumer goes directly into PowerLender and loan-status updates are available on the web.

****Aside from the large number of technical and business requirements that PowerLender was able to handle, it’s still a user-friendly system. I manage 16 people who touch PowerLender on a daily basis, including originators, processors, underwriters, closers and post closers. They are all involved in the process, and their input is extremely important.

****We achieved our lending technology requirements of an in-house system that could handle multiple lending products including consumer, and deliver integrations to streamline the point-of-sale.

****Technology that provides flexibility, adaptability and ease of use is a key to a long-lasting LOS. Having a vendor who understands our business as well as theirs is just as important to achieving success. And when you achieve a comfort level among all stakeholders, it allows for rapid acceptability and real achievement.

****The next ‘Lender Spotlight’ shines on an innovative lender who used technology to compete on a higher level.

Market Analysis: Look At The Landscape

*Look At The Landscape*
**By Tony Garritano**

***Excuse me today my friends. I’m a bit tired. I was up until 3 a.m. waiting for the results of the Iowa Caucus. My friends know that I’m a political junkie. What happened yesterday in my view was amazing. A conservative state voted for a candidate that didn’t match their ideals absolutely. Why did they do that? Because Iowans realized that it’s not about who is the most conservative, it’s about who can save our country from the failed policies of this White House. Kudos to Iowans for reassessing the landscape and taking a second look to pick the most electable, and competent, candidate. Similarly, prominent mortgage technology vendors are always reassessing the best way to serve this ever-changing mortgage market. For example, PROGRESS in Lending has learned that Franklin, Tenn.-based Wipro Gallagher Solutions has redefined its fulfillment offerings to more clearly meet the demands of loan originators and servicers for middle- and top-tier lenders. What does that mean? Here’s the scoop:

****For originators, WGS has revised its BPO offerings depending on the lender’s volume of originations and service offerings. WGS now offers originators its services through the following packages:

****>> Platform BPO Fulfillment Solution– offers an end-to-end mortgage origination fulfillment solution including all services from the point of application. Utilizing shared resources and technology based out of the Nashville Delivery Center.

****>> Integrated BPO Solution– tailored to meet the client’s specific needs and is inclusive of support-functions in the areas of loan processing, loan underwriting analysis, closing, funding coordination and post-closing delivery. The delivery staff works within the client’s existing technology and workflow process.

****>> Traditional BPO Solution – provides support for lenders on full functions within the loan process such as processing or post closing or sub-functions of these roles. Clients provide the standard loan lifecycle processing functions while WGS’ global team provides integrated back-office support. Work is performed based upon client-specific processes and procedures.

****For loan servicers, WGS now offers the following product suites tailored to fit their needs:

****>> Complete Subservicing Offering– supplies a complete private-label solution in partnership with a leading U.S.-based sub-servicer. This end-to-end offering enables significant per loan cost savings to each client.

****>> Back Office BPO Solution– supports full functions within the servicing stream including payment processing, reconciliations, loan modification, loss mitigation, and more. The delivery staff works within servicer’s existing technology and workflow process.

****“Wipro Gallagher Solutions has reorganized its private-label BPO offerings into packages that are simple to understand and are tailored to specific markets,” said Narayan Bharadwaji, business head for WGS. “The new packaging better serves our customers to fit their specialized needs and provides more flexibility to enable our customers to focus on their core business and target markets.”

Life-Cycle Lending:Technology Advances

*Technology Advances*
**By Harvey Foster**

***There is no question that technology advances such as multi-vertical origination software have enabled financial institutions to implement customer-centric business models. Lenders certainly need to be nimble when it comes to product and process. But it does not stop there. Financial institutions need to add a new word to their lexicon: transparency. This term is becoming foundational to how the loan operation relates to regulators, borrowers and other departments within the institution. Transparency is not only being able to provide insight into origination processes and practices, but it also means being able to pass along transactional data to those who request it, when they request it and in the format they request it.

****Looking back as far as a decade, some astute financial institutions began to realize that their loan origination systems were becoming outdated and were based on technology that was increasingly more difficult to maintain. But the influx of new loans suppressed system upgrade projects. As a result, the current technology landscape is rife with redundant, inefficient, and incompatible systems that are increasingly costly to maintain. The long-term result of this uncoordinated growth was a focus on vertically segregated products and a business-line approach to managing customers.

****Many institutions have grown accustomed to having one system for first-lien mortgages, another system for second liens, a third for lines of credit secured by real estate, and possibly even a fourth system to accommodate other consumer installment products. In such a stratified operating environment you may also find deployment of separate systems to help manage collections and investor accounting in an attempt to bring cohesion to disparate servicing systems. Aging components and a mixed bag of interfaces jeopardize the entire lending infrastructure. The risk of failure increases and the cost to maintain status quo escalates rapidly. Cost and risk pressures prevent some institutions from installing upgrades that are critical to their business.

****The future of origination technology resides with multifunction, multi-vertical solutions. New systems, such as Common Origination Platform from Fiserv, will be used to support multiple loan products, both secured and unsecured. To keep operations nimble, these solutions will have embedded rules and other controls to empower lenders. They will also be real time to ensure immediate awareness of transactions across the enterprise.

****Common Origination Platform and other systems like it combine intelligent processing automation with next-generation, sophisticated technology architecture. With customer data housed in one database, lenders can effectively reduce risk, gain processing efficiencies, take advantage of cross-sell opportunities and use information more effectively across the enterprise.

****Process Automation

****Offering process improvements and greater levels of automation, single platform environments such as Common Origination Platform enable financial institutions to originate all consumer, business and mortgage loans utilizing the same tools (including all processes, workflows and business rules management performed) and skill sets. Defining or modifying actions, behaviors and workflows within this environment is easily accomplished by manipulating the built-in business rules, giving an organization much greater control over its own specific processes. Streamlining in this fashion can open up new avenues for cost management strategies and greater profitability.

****Single System IT Support

****Operational efficiency is built into an integrated platform. Having just one system means that any updates, changes or modifications are applied enterprise-wide, saving resources and money. Systems such as Common Origination Platform that can handle multiple loan types across multiple channels enable the organization to devote IT resources to maintaining and supporting just that system. A common platform also eliminates the need to train separate technical staff or users to handle different technology applications.

Market Analysis: Compliance Remains Paramount

*Compliance Remains Paramount*
**By Tony Garritano**

***Are you frazzled dealing with all the new rules and regulations? Aren’t we all? In most cases, it’s the job of your vendors to keep you compliant. And the good ones are doing just that. Fior example, PROGRESS in Lending has learned that LOS Avista Solutions has completed a direct integration to ComplianceAnalyzer, an automated compliance auditing solution from risk management solution company ComplianceEase. Here’s the scoop:

****Avista Solutions and ComplianceEase have a number of mutual customers and this integration allows those customers to access the ComplianceAnalyzer solution directly from their Avista Agile LOS.

****ComplianceAnalyzer gives mortgage lenders real-time compliance audits at any point in the lending process, safeguarding them from potential loan risks. As part of recent electronic examination (e-Exam) initiatives, state regulators have been using ComplianceAnalyzer and other e-Exam tools to audit as much as 100% of licensees’ loans in regulatory examinations. By leveraging integrated audits using the same auditing software, lenders can prepare in advance for their e-Exams. ComplianceAnalyzer covers a full spectrum of government regulations, including the Home Ownership and Equity Protection Act, the Truth in Lending Act, RESPA, state and local anti-predatory lending laws, state license-based consumer lending regulations and secondary market investor and GSE compliance guidelines.

****“Avista Solutions recognizes the importance of providing our customers with access to industry leading compliance tools,” Avista Solutions COO & CFO Jerry White said. “As the company behind robust tools that state banking and mortgage regulators rely on, ComplianceEase is a significant force in the mortgage industry and we are excited to now offer a seamless, system-to-system interface to their ComplianceAnalyzer solution.”

****Avista customers who choose to sign up for ComplianceAnalyzer may utilize the tool to pinpoint a mortgage loan’s compliance risk factors, whether the loan is in the pre-close or post-close stage, with a single click and without leaving their Avista Agile LOS. ComplianceAnalyzer returns comprehensive, user-friendly audit reports to lenders within seconds. Each report features the industry standard RiskIndicator, a score that reflects a loan’s compliance risk, as well as quantitative analysis of thresholds and detailed qualitative overviews with narrative descriptions of regulatory requirements.

****“Avista users can enjoy the best of both worlds with this seamless integration, continuing to use their LOS of choice, while managing compliance with ComplianceAnalyzer,” said ComplianceEase Senior Vice President Jason Roth. “Major secondary market investors use ComplianceAnalyzer to check every loan prior to purchase and state regulatory examiners are using it to audit as much as 100% of licensees’ portfolios. To safeguard their reputations and reduce financial risks, it makes a lot of sense for lenders to do the same.”

Powering Today’s Lenders: Let’s Put The Spotlight On The Lender

*Let’s Put The Spotlight On The Lender*
**By Daniel Liggett**

***This is the first article in our ‘Lender Spotlight’ series where we share stories from actual lenders about how they select and implement technology initiatives. Each story is told by the decision-makers themselves and describes in detail, the thought process behind their choices. This week’s ‘Lender Spotlight’ focuses on Florence Savings Bank in Ware, Massachusetts.

****Too often during searches for new lending technology, the majority of the focus is placed on the functionality and capability of the product, and the importance of vendor quality is either undervalued or overlooked.

****This can be highly detrimental to a lending organization in search of enterprise-wide technology because the quality of whom you deal with can be the determining factor in the degree of success that is achieved with the technology.

****Florence Saving Bank, a $1.1 billion lender in Central Massachusetts performed quite a bit of due diligence before deciding on an LOS. We, like many others, were bogged down with regulation changes and could no longer tolerate the maintenance, inefficiencies and limitations of their antiquated LOS of ten years. We wanted a flexible, online solution that could handle both mortgage and consumer lending. Vendor quality was of concern after experiencing a decline in support over the lifetime of their LOS.

****Jeff Smith, Vice President at Florence Savings, and his team prepared a detailed list of functionality that they required. They looked at nearly a dozen LOSs, choosing three or four to review in depth. None of them handled all of our requirements, nor did any differentiate themselves from the other.

****We then began hearing success stories from lenders using an LOS, available from an area reseller, that wasn’t even on Florence Saving’s initial list of candidate systems. We grew more interested as the varying lenders we encountered described the RemoteLender LOS provided by Specialized Data Systems. The more we listened, the more we were intrigued that this single LOS was able to meet the varying needs of the different lending operations and I was especially surprised when each lender repeatedly cited SDS’s high level of service as a determining factor in their success.

****Armed with this feedback, we then performed an in-depth technical review of RemoteLender and also scrutinized SDS to determine their viability, experience and capability as a vendor. It was important to Florence that SDS could handle the implementation and customization of the LOS, as well as all phases of ongoing maintenance, including monitoring compliance issues.

****After passing the most exhaustive review of any technology in its history, we chose RemoteLender. SDS went to work assessing the banks’ requirement, developing a phased implementation project plan and refining RemoteLender to fit our lending model.

****We received great support from SDS during the rollout phase. We had weekly scheduled conference calls to keep us on task and set forth milestones to monitor our progress. With SDS being essentially a ‘local’ vendor, they are here for us to provide the support and business services that we need to achieve our goals.

****SDS handles all of the custom reporting and integrations, and since RemoteLender is deployed online, SDS continues to maintain all hosting functions (through a third-party) including all IT, security, backup and connectivity tasks.

****Our RemoteLender is not like any other banks’ system, it does what we want it to do the way we want it. We are fortunate to have SDS as our vendor because we plan to keep RemoteLender for 10-15 years.

****The key to a long-lasting LOS is performing the due diligence on the vendor as well as on the functionality. The quality of the vendor and the level of service they provide are essential to getting the most from your technology and achieving your lending goals in the most cost-effective manner.

****Next week’s ‘Lender Spotlight’ focuses on an Eastern Connecticut lender who chose PowerLender deployed in-house.

Life-Cycle Lending: Optimizing Technology Across Verticals

*Optimizing Technology Across Verticals*
**By Harvey Foster**

***Lagging technology is a key cause of higher operational costs and organizational inefficiency, which negatively affect both profit margins and the borrower experience. For lenders using numerous lending platforms to manage various loan products, the challenges associated with aging technology are only multiplied. In uncertain markets, IT budgets are quickly eaten up on maintenance and compliance initiatives, with little left over for new products, services and capabilities.

****Maintaining different technology platforms across lending silos also breeds duplication of effort, redundant processing and IT support, and inefficient use of valuable staff resources. Since each platform is unique, there is virtually no standardization of processes, procedures or best practices.

****Disparate Lending Platforms Deliver Operational Inefficiencies

****Lenders that utilize different loan origination systems to support mortgages, business loans and consumer products cannot help but find operational inefficiencies lurking around every corner. Multiple platforms inhibit enterprise-wide customer views and data utilization. As a result, cross-sell opportunities are missed, communication both internally and with the borrower is ineffective, and customer data retrieval and verification are inconsistent.

****Lending platforms often utilize entirely different processes and procedures, severely limiting the ability to have a collaborative lending strategy on an enterprise scale. A multiple-platform approach also triggers inconsistent decisioning, which lengthens the loan origination process and impacts profitability. This approach can even affect the borrower experience, as inefficient processing dashes customer expectations for “right now” loan options, approvals and documentation. Further, since each system requires maintenance and support, there is significant – and costly – duplication of effort, driving up operational costs and wasting manpower.

****Challenges Posed by Inefficient Technology

****In a poll conducted by Fiserv in late 2009, 40 percent of respondents indicated that they have the right business strategy but need to better leverage technology. When asked if their technology enables them to keep pace with the current lending environment, nearly one-third said they wished they were better at leveraging opportunity.

****The figures are telling and suggest some of the circumstances faced in the executive suite relative to lending strategy going forward.

****>> Chief Operating Officer – Developing, enhancing and maintaining efficient organizational processes can be severely challenging for organizations. The reporting and monitoring of operational metrics for multiple lending platforms is labor intensive and cost prohibitive. The effort required to promote best-practice processes across verticals can divert attention away from more beneficial duties, such as fine tuning day-to-day performance to promote company growth, increased profitability and future expansion.

****>> Chief Information Officer – Directing data information and integrity throughout the organization can be problematic. Each lending system has its own technology, making the infrastructure and networks extremely difficult to manage and maintain. Disparate loan systems may not link together, making the validation and certification of customer data exponentially more challenging for the CIO and the organization.