We received a request from a company called Geosegment Systems for our 2008 modified HMDA data. Has anyone else heard of this company or received a request? They have very little information on their website.

Thanks

We received a similar letter yesterday from this firm. Like you I looked at their website and it appears that they provide market data for a fee to interested parties. If your letter is like the one they sent to us, it requested that we provide them with our 2008 modified LAR Register. Their letter went on to further say that by law, specifically Section 203.5(c) of Reg C, we were required to provide this firm with our data, that they wanted the bank to submit the data to them in a certain way and they ended their letter by saying “Thank you in advance for your compliance with this federal law.”

The bank is required to provide a modified LAR to the public when a request is received. Normally whenever we receive a request, we print off a copy and provide it to the requestor at no cost. The firm’s letter, however, rubbed me the wrong way. Section 203.5(d) of Reg C also provides guidance to financial institutions on how to make this information available to the public. We anticipate citing and utilizing this section of Reg C to our advantage when we respond to this firm about our data.

Thanks for your response. I also felt the letter rubbed us the wrong way. The wording was quite forceful. I also plan to use section 203.5(d) of the regulation to require a fee for this service.

I believe more banks will be receiving the letter since it is obviously a form letter.

I would also tell them that you only make it available in paper form (there is no requirement that it be electronic). Since they are trying to strong arm you and they appear to be attempting to sell the information, I would make it as miserable for them as I could under the regulation.

So, lscy, are you going to e-mail them to let them know you are requiring a fee? We are thinking we want to as well.

Not Iscy, but we did e-mail this firm, cited section 230.5(d) of Reg C and advise them that there would be a charge for providing or reproducing our data in the manner requested. We gave them the amount for this “reasonable” fee and further told them that these funds would need to be received by this bank in the form of guaranteed funds prior to the delivery of the requested information.

Thanks Jon D, that is what we are intending to do as well.

We have not yet contacted the firm to inform them of our fee. My regulator is looking into it right now. His concern was that they did not state what the information will be used for.

Does it matter? Isn't the Bank required to give it to anyone who asks?

Don't you think that $1,000 is a reasonable fee?

seems a little low for a co that is going to sell the information

I want to repeat what Randy said above. DO NOT provide it to them electronically. They will slice and dice your data easily and look for fair lending issues. Print it out or make them copy it.

So....does the word "electonically" include burning it to a CD? In other words, a hard copy version should be the only choice?

I wouldn't give it to them in any format they could use to manipulate your data.

I'm just dying to know what these guys are up to and how many other banks they have sent their ahem, 'request' to.

Electronically means any means that would allow them to easily download it onto a computer and begin the 'slice and dice' David mentions.

Hard copy is all we'll ever give anyone. If they want to analyze it, they can hire someone to load it on their system.

I just had some feedback from one of my clients that received the same request. They told them that it was going to cost about $100 to produce and mail the LAR to them (large LAR) and that they would only provide a paper copy. They backed off and they have not heard from them again.

Good to hear Randy. They want it easy and cheap.

I wish I had seen this thread earlier. Just this morning I sent them a pdf of the DAT document that is generated from the Fed's software.

I just got an e-mail thanking me for my "courteous response."

I sent them a PDF as well, BUT I took my modified LAR, scanned it to a PDF and purposely made none of the text or data selectable. So, they can't select anything or copy/paste anything. Essentially, they would have to manually input the data, as if I had mailed them a copy.

Great idea dmk2006 - we received another request for our data electronically after we quoted a price of $100.

"May I ask why the cost of your HMDA data would be $100 for a hard copy? I would think that a more reasonable fee could be achieved by making us an electronic copy."

I think we will follow suit with what you have done.

Any others still working with these guys?

Since I'm that the one that started this discussion, here's our update.

We also informed them of our fee ($100 plus cost of copying for a total of $125) and told them we would provide a hard copy after we receive their guaranteed funds. We have not yet heard back from them, but if we do, we plan on providing hard copy only.

I looked at it this way - they got it electronically in a format they requested, I complied with their request - they can't complain. I saved us the postage and paper for mailing it, and the time and energy of having it on my to-do list for more than a day. And if they want to use the data, they will have to have to pay someone to sit and manually enter the data from the report. I have the email from them confirming they received it, thanking me for my prompt response, and it's filed away!

We were just contacted. Has anyone actually sent them paper?

Before you send any data, be sure to read the 2 blogs I wrote on this topic. "HMDA Data Requests" and "HMDA Data Requests - Part II" can be found at our blog archive page:
http://www.bankerscompliance.com/blog-archive.htm