This is wrong!!! Request for HMDA Data for Profit.
I was just reading a letter that was sent by a company called Compliance Technologies to one of our clients. The letter was requesting the 2005 Public Data in agency submission format. The letter also stated that the data would be combined with the top 300 volume submitters in the industry so that they could market the data with their product HMDAWare Online. The letter further went on to say that they will request this data in the future before March 1st, every year. I find this request offensive on many levels: 1) This is not what the spirit of the public data was about. The Public Data release was designed to give community groups and the public access to the data if they felt there was something they needed to look at for a particular institution. Not so a company could collect the data early and try to make a profit on the data. 2) They are requesting the data in agency submission format. First of all, it is illegal to send the agency format to a non-government agency for privacy reasons. Most HMDA software products can not create public format submission files (without app numbers and dates). Comply can, but that is besides the point. Secondly, you are only required to send the data in public format. That could be on paper, or in PDF format if you want to be a little nicer. I personally would send Compliance Technologies a letter stating that there is a $.05 per page charge for the data and you will be sending the requested data on paper. You can actually charge a reasonable cost for copying the data! 3) Then they went on even further to say that they would be requesting the data every year prior to March 1st. Well you are only required to send the data 30 days after March 1st. And again, I would send it on paper and charge them. RATA could have been requesting data from our customers and the industry as well over the last few years for use in our peer analysis software, but the data released by the government has gone through many layers of scrubbing, editing and consolidating. There is no way that the early compilation of the data will match the end result. Plus this company is providing this data to the Department of Justice for early preview. I don't think I would want my premature data sent there any sooner than it had to be reviewed. Has anyone else received this letter? Please let me know your thoughts. Thank you.
We haven't received the letter/request (yet). The nerve of them! I appreciate the heads up and like your suggestion of paper- we would certainly keep them busy with our submission count!
Personally I prefer the rich text format. Same effect as the paper reports, but they have to kill their printers intead of killing yours [}:)].
I received one of these letters and am not happy about it. I like the idea of charging them a fee and sending about 2,000 pages for them to key in.
We received the letter and it is quite offensive. My first instinct is that it's a person or group of people trying to start a business of pointing out who may be discriminating or extortion to not announce to the world a company is discriminating. You cannot send them agency format data - if you send the data it has to be void of the loan number and any other information that might identify the customer. Because we are required by law to respond I plan on sending them an invoice to pay for my copy in advance. If they do decide to pay, I'll send the report.