Q4 2009 - 2017:
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We continue to monitor this topic closely and expect to continue making minor adjustments to the logic around Q throughout the year as we learn more from the CFPB. We are currently evaluating batch generation of the ULI at import. Check Digit calculations are universal.
QuestSoft has hosted a number of webinars to provide information on what is changing, what you need to look out for, and what your organization needs to do. Sign up to receive notifications of upcoming webinars from QuestSoft. We have assembled all submission related information on our Submission Central website. It answers all of your burning questions about the new submission process. Rest assured, QuestSoft will be here to assist you at every step along the way.
Yes, the Rate Spread calculation method has not changed. QuestSoft has always calculated the Rate Spread per the regulation. Our Instant Geocoder software boasts the highest accuracy rates in our industry.
As of November, the CFPB geocoding platform has yet to be released, but rumor has it that it will use less accurate publically available data, thus the offer of "Safe Harbor". Pages indicate the following:. Obtaining census tract numbers using other geocoding tools may constitute a procedure reasonably adapted to avoid geocoding errors, depending on the facts and circumstances.
If a financial institution chooses to use an alternative geocoding tool that constitutes a procedure reasonably adapted to avoid census tract errors, the financial institution will receive the same Safe Harbor protections.
We understand the default of examiners will be the CFPB Geocoder, especially if they are not well versed in geocoding. However, while the Bureau has yet to release its geocoder, their statements indicate the use of free sources that traditionally have not measured up to acceptable accuracy of current examinations. We feel the likelihood of errors may double or triple with these databases despite any safe harbor. Therefore, QuestSoft feels the only way for an institution to protect itself and for the industry to maintain trust and integrity in the loans it is making, is to always judge a geocode on its accuracy.
We are also contemplating several solutions, which are all dependent on the CFPB releasing an open source geocoder. We know that many of our customers miss the old LAR form.
Unfortunately that format is no longer feasible or printable with HMDA fields. To simplify the form, we have combined the GMI fields. Please note that this report is not to be used for submission or re-importing into the software. If you missed our recent S.
Here you can mark your institution as exempt. Additionally, you will have several data points available to mark that your institution chooses to report, regardless of your exemption status sort by LAR order, or Alphabetically. After the Exempt Institution option is checked, when viewing a loan record you will now have the following new options at the top right of the screen:. We have also created an internal field reconciliation and identified the value of all exempt fields.
The beta testing period typically starts in early December and will close on January 1st. After January 1st, you will be able to upload data into the official version of the Platform. See answers to frequently asked questions below! The Q Quality Edit is intended to identify a potential error. If the error is systemic in nature, the reporting entity must make the appropriate correction prior to submission.
Yes, we will offer the ability to verify the check digit on every ULI. Who can register the company: You must currently be an employee of the company you are registering, and be authorized by the company to register for an LEI. Alternatively, financial institutions may use a third party through an assisted registration process.