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• Cognizant 20-20 Insights




GSE Loan Delivery: Interim Analysis
and Approach
   Executive Summary                                         benefits of the UMDP program, as well as the
                                                             implementation challenges faced by players
   While the recent housing crisis can be attributed
                                                             across the mortgage industry. It concludes with
   to a number of factors — low interest rates, exotic
                                                             an approach for deploying business and techno-
   products, lack of audit controls, inadequate
                                                             logical improvements that can reduce risk and
   credit risk analysis, insatiable investor appetite,
                                                             optimize the entire loan origination process.
   predatory lending and irresponsible borrowers
   — one of the key factors was the non-availability         UMDP Program Overview
   of consistent, accurate and detailed origination
                                                             The GSEs announced the launch of UMDP on May
   data. This problem has led to inadequate consid-
                                                             24, 2010, under the directive of the FHFA. UMDP is
   eration/evaluation of several of the factors stated
                                                             aimed at helping organizations implement uniform
   above.
                                                             appraisal and loan delivery data standards, which
   Government Sponsored Enterprises (GSEs),                  would facilitate data accuracy and integration of
   Fannie Mae and Freddie Mac, created the Uniform           mortgage data across the industry landscape. As
   Mortgage Data Program (UMDP) at the direction             depicted in Figure 1, this program comprises three
   of the U.S. Federal Housing Finance Agency                components.
   (FHFA). UMDP aims at significantly improving the
                                                             While the technical requirements and specifica-
   depth, breadth and quality of data throughout
                                                             tion for UAD and UCDP are identical, the ULDD
   the mortgage life cycle to promote transpar-
                                                             requirements are not consistent for both GSEs
   ency, accountability, compliance and better risk
                                                             in the case of conditionally independent2 data
   management. This white paper discusses the
                                                             points.

   UMDP at a Glance
         Component                         Objectives                                Data Elements
    Uniform Appraisal      Improving data quality by having uniform       209 data points.1
    Dataset (UAD)          standards for capturing appraisal data.
    Uniform Loan           Improving data quality by having uniform       Over 600 data points, approximately
    Delivery Dataset       standards for capturing loan delivery data.    half to be implemented in Phase l and
    (ULDD)                                                                the rest over time.
    Uniform Collateral     Facilitating electronic submission of          UAD includes all the data points
    Data Portal (UCDP)     appraisal data files to the GSEs through the   required to complete the appraisal
                           uniform residential appraisal report form.     report form.
   Figure 1




   cognizant 20-20 insights | april 2012
A Step in the Right Direction                                                            •	 LOS vendors: Numerous banks have installed
                                                                                               these platforms to originate thousands of
UMDP represents an attempt to address the
                                                                                               loans per month. LOS vendors will be the key
various data issues plaguing the industry.
                                                                                               drivers of ULDD implementation as they will
Supported by UMDP, the breadth and depth of
                                                                                               need to enhance and roll out their products
loan data — delivered on a timely basis through
                                                                                               across several banks.
a common industry standard — will lead to signifi-
cant improvements in transparency for investors,                                         •	 Originators:       These companies have the
as well as strengthen risk management capa-                                                    ultimate responsibility to be ULDD compliant
bilities, lender accountability, secondary market                                              as they will be responsible for submitting loans
pricing and reporting/analytics. This initiative                                               in prescribed format to the GSEs.
will not only lay out the foundation for future
controls, but also be essential in bringing back
                                                                                         •	 GSEs:      These organizations will need to
                                                                                               enhance several internal systems to incorpo-
investors to the secondary market.                                                             rate enhanced data into their existing pooling,
                                                                                               pricing, trading, investor reporting and
Timelines and Impact Analysis                                                                  analytics systems.
The GSEs have laid down specific timelines to
implement the components of UMDP, which                                                  •	 Third-Party        Service Providers: Appraisal
                                                                                               management companies will need to start
starts with implementation of UAD by September
                                                                                               providing data in the required format to origi-
1, 2011, to implementing ULDD by November 2012.
                                                                                               nators through their existing delivery channels
Key timelines and impact analysis on key players
                                                                                               and will need to enhance their delivery channels
is summarized in Figure 2. Key participants
                                                                                               to provide adequate data depth and breadth
impacted will be loan origination system (LOS)
                                                                                               per UMDP. They will also need to update forms
product vendors, originators, GSEs, third-party
                                                                                               for their vendor network that actually process
service providers, rating agencies, investors and
                                                                                               the orders.
servicers.


ULDD Transition Timeline

           Sept. 1, 2011                   Dec. 1, 2011                    March 19, 2012                   July 23, 2012                    November 2012
    UAD                           ULDD                                 UCDP                           ULDD                                ULDD
      All appraisers must          All loans with application           Appraisal report must be       Loans with an application           All loan deliveries on or after
      complete the appropriate     received dates on or after this      submitted to the UCDP if:      received date on or after           this date must include the
      appraisal forms as           date must include the applicable       The loan application is      December 1, 2011, that are          two additional data points
      required by the UAD.         ULDD data points for Phase I.          dated on or after            delivered to either GSE on or       required by the SEC.
                                                                          December 1, 2011, and        after July 23, 2012, (previously
                                  UCDP                                                                                                     The exact date is yet to be
                                   For loans with application                                          March 19, 2012) must meet the
                                                                         An appraisal report           ULDD Phase I requirements.          communicated.
                                   received dates on or after this       is required.
                                   date, the appraisal report form,                                   UCDP
                                   if required, must be submitted       Doc File ID (ULDD data         Doc File ID (ULDD data point
                                   to the UCDP prior to delivery, if    point Appraisal Identifier)    Appraisal Identifier) is
                                   the loans are delivered on or        is not required at delivery    required at delivery on or
                                   after March 19, 2012.                until July 23, 2012.           after July 23, 2012.

                                                                              IMPACT
    UAD                           ULDD                                 UCDP                           ULDD                                ULDD
      Originators/LOS Vendors      Originators/LOS Vendors              Originators/LOS Vendors        Originators/LOS Vendors             Originators/LOS Vendors
       Enhance systems and          Enhance systems and prepare          Enhance systems and            Enhance systems and                 Enhance systems and
       prepare staff to support     staff to support and process         prepare staff to make          prepare staff to support            prepare staff to support
       and process new UAD          data per ULDD.                       final preparations for         and process data per                and process data per final
       compliant forms.            Third-party Servicers                 mandatory delivery of          ULDD.                               ULDD requirements.
      Third-party Servicers         Enhance systems and prepare          appraisal forms through        Final preparations for the         Third-party Servicers
       Enhance systems/forms        staff to support ULDD.               the implementation             delivery of ULDD Phase I            Ensure that they provide
       and train vendors/staff                                           of the UCDP.                   loan data.                          the required data elements
                                   GSE
       on using the new             Enhance several internal             Ensure users are                                                   to lenders required per SEC.
                                                                         configured in UCDP.
                                                                                                      UCDP
       appraisal form.              systems to move from current                                       Originators/Third-party             Servicers
                                    data breadth and format to                                         Servicers                            Enhance systems to process
                                    new standards.                                                                                          loans with enhanced data
                                                                                                        Upload appraisals to the
                                  UCDP                                                                                                      requirements and investor
                                                                                                        UCDP, working with
                                   Originators/LOS Vendors                                                                                  reporting.
                                                                                                        vendor if applicable, to
                                    Enhance systems and prepare                                         capture and store the              Rating Agencies/Investors
                                    staff to support and process                                        Appraisal Identifier data           Enhance pricing models
                                    data per ULDD.                                                      point (DocFileID) for               (data and logic) to include
                                   Third-party Servicers                                                delivery with the ULDD.             enhanced factors in price
                                    Enhance systems and prepare                                                                             determination.
                                    staff to support ULDD.



Figure 2



                                  cognizant 20-20 insights                                2
•	 Rating Agencies/Investors: Both will need to              access controls and accountability for each
  enhance their pricing models in terms of data              field. This will be a challenging task given
  and logic to include enhanced factors in price             the fact that detailed analysis of hundreds of
  determination.                                             screens, scores of roles and hundreds of fields
                                                             will be required to achieve this along with cor-
•	 Servicers:These companies will need to
                                                             responding validations.
  prepare for boarding and managing loans
  with enhanced data requirements as well as             •	 Training    and Change Management: Given
  enhanced and consistent investor reporting.                the number of parties involved and extent of
                                                             changes required, training the staff to adapt
Implementation Challenges
                                                             new fields will be a difficult habit to break.
ULDD implementation across various systems                   Analyzing the impacts on business processes
and stakeholders is not without challenges. The              and swiftly aligning them to go in hand with the
challenges include multiple parties and stake-               changes might turn out to be another compli-
holders with conflicting priorities, extensive               cation during the implementation.
customizations, multiple installations, training
and change management, coordination and                  •	 Changes to Data Warehouse Infrastructure:
embracing a unified view of these changes.                   Any changes to the source systems will have
Specific challenges include:                                 a corresponding impact on the DW. Originators
                                                             should implement the changes to the DW along
•	 Multiple Parties and Stakeholders: Successful             with the source systems to avoid inaccuracies
  and timely implementation of UMDP is                       in the reports generated and analysis done
  possible only through seamless coordination                with the data in the DW.
  between various stakeholders — originators,
  LOS vendors, third-party service providers
                                                         •	 Tight    Data Dictionary and Edit Checks:
                                                             The GSEs have published a very tight data
  and various units within these entities (IT,               dictionary for loan delivery with several
  business, data warehousing (DW), etc.). Given              business rules at field level. The XML file will be
  the different priorities of these stakeholders             rejected if the supplied data does not meet the
  and their business units, this is easier said than         specified guidelines. This would lead to extra
  done.                                                      programming effort in terms of building these
•	 Product   vs. Client-specific Requirements                rules up front into the LOS, as well as checking
  and Customizations: LOS vendors and origina-               prior to loan delivery. Exception reports and
  tors are struggling with identifying, managing             exception analysis and remediation teams may
  and implementing changes to their disparate                be required for an initial period to overcome
  versions of systems, as considerable custom                these challenges.
  code has been added on top of base products.
  For some originators, particularly those that          Suggested Approach
  use plain vanilla features, this change might be       A solution approach to implement UMDP
  easier to make and manage, but for those that          requirements comprises a unified plan and
  have customized the platform significantly,            governance model across various stakeholders
  identifying and implementing changes will be           and units within them, GSE data dictionary-driven
  difficult given the limited availability of LOS        approach, and a deeper/long-term view of imple-
  vendors’ professional services teams. Updates          mentation. As depicted in Figure 3, the approach
  to the customized origination products for a           would start with the GSE data dictionary, identifi-
  variety of clients (as mandated by UMDP) are           cation of data gaps, and a determination of how
  a daunting task for product vendors. Simul-            to holistically fill these gaps, followed by an imple-
  taneously, product vendors will need to make           mentation plan. Additionally, the implementation
  updates to their core products to facilitate new       approach should be flexible and extensible to
  implementations in the future.                         conform to future enhancements with the imple-
                                                         mentation of an extensible business rule engine
•	 Simple   Field Additions Will Not Help;
                                                         to check and compare each data element against
  Role-based Access and Accountability Is
                                                         documents (images/PDFs) and data point source
  Required: LOS vendors and originators who
                                                         system information to ensure data accuracy and
  view this simplistically (i.e., just add the fields)
                                                         consistency. An effective audit trail should be
  will not be able to take true advantage of this
                                                         generated to track the prefunding reviews and
  opportunity if they do not take into account




                        cognizant 20-20 insights         3
An End-to-End UMDP Implementation Plan

                                                     Data Gap to Business
           Identify Data Gaps                    Function/Role/Screen Mapping                       Define and Prioritize

      • GSE data dictionary is the               • Map each    data gap to business           • Sound change management
        starting point.                             process/function and role.                 practices to enhance systems and
      • Map current data set to                  • Map each gap to various applications;       business process to capture data.
        GSE data dictionary.                       start upstream and traverse                • Implement through unified
      • Identify gaps — data/depth.                downstream.                                 governance model.
                                                 • Define business rules for each
                                                   data element.
                                                 • Define document, field and system
                                                    mappings for comparison.

Figure 3


              Data Sources               Master Data
changes to reduce buy-back requests from the                                Transform                       Edit Checks
                                                                    Conclusion
GSEs/investors (see Figure 3).
   • Consolidate all data in      • Maintain in enterprise          UMDP is a data to in the •rightcomparison across bring
                                                                       • Transform step               Data
                                                                                                             direction to
     single DW for effective        data definition and
As with data submission guidelines for various                      transparency and accountability among various
                                                                         UMDP standards.              system and documents.
     control & distribution         control repository.                                             • Check data rules before
loss (Sources will beprograms on • Transform &
      mitigation LOS, POS,        the servicing side -              stakeholders. UMDP not only provides trans-
                                                                                                      submitting.
     Lead, CRM etc.).                                               parency and accountability butmanagement the
                                    standardize data.
Home Affordable Modifications Program (HAMP)                                                        • Exception also lays
   • Up-front implementation      • Source of truth across                                            & resolution.
                                                                    foundation for possible restart of the secondary
and of rules inAffordability Foreclosure Alternative
      Home source apps to           the enterprise.                                                 • Submit to GSEs.
     capture the data points
(HAFA) — the datarules                                              loan market. Delivering high-quality data to
     through business dictionary for UMDP is equally
tight and could be a cause for concern. These
     engine.                                                        investors in a consistent and timely manner will
constraints should be handled at the LOS appli-                     allow investors and rating agencies to effectively
cation and data submission/DW stage by building                     evaluate, rate and manage risk associated with
the rules up front in the application as well as                    mortgage investments.
downstream (prior to submission). Originations
                                                                    While UMDP will require up-front investment from
IT/DW should take guidance from their servicing
                                                                    various participants such as lenders, vendors,
counterparts who have already implemented
                                                                    servicers, investors and rating agencies, in the
a process very similar to UMDP for various
                                                                    long run all parties will benefit from improved data
government programs. As depicted in Figure 4,
                                                                    quality and transparency and business processes
the ideal architecture should comprise data con-
                                                                    enabled by a technology refresh and resultant
solidation and standardization across sources,
                                                                    new business opportunities. This industry-wide
                                                   Data Gap to Business
transformation, Data Gaps
           Identify edit checks and corresponding
                                            Function/Role/Screen Mappinglead to a moreand Prioritize efficient,
                                                                    effort will
                                                                                             Define
                                                                                                         transparent,
exception management and submission. This
                                                                    consistent and streamlined operations and risk
would GSE data dictionary is the
      • provide a single source for data definition gap to business
                                            • Map each data                           • Sound change management
        starting point.                       process/function and management for all industry participants. Loans
                                                                     role.               practices to enhance systems and
management (e.g., set to definition • Map each gap to various applications;
                            data              repository),
      • Map current data                                            supported by UMDP will fostercapture data.
                                                                                         business process to an environment
accessGSE datadistribution across the start upstream and traverse
          and dictionary.                      enterprise,                            • Implement through unified
                                              downstream.           of trust leading governance model.
                                                                                          to improved participation in the
while•taking into — data/depth. UMDP requirements.
        Identify gaps account the
                                            • Define business rules secondary market.
                                                                    for each
                                                  data element.
                                                • Define document, field and system
                                                  mappings for comparison.
UMDP Implementation Data Flow


            Data Sources                    Master Data                      Transform                        Edit Checks


   • Consolidate all data in          • Maintain in enterprise          • Transform data to           • Data comparison across
     single DW for effective            data definition and                UMDP standards.              system and documents.
     control & distribution             control repository.                                           • Check data rules before
     (Sources will be LOS, POS,       • Transform &                                                     submitting.
     Lead, CRM etc.).                   standardize data.                                             • Exception management
   • Up-front implementation          • Source of truth across                                          & resolution.
     of rules in source apps to         the enterprise.
     capture the data points
                                                                                                      • Submit to GSEs.
     through business rules
     engine.


Figure 4



                               cognizant 20-20 insights                4
Footnotes
1	
     A “data point” is the term name that must comply with Mortgage Industry Standards Maintenance Orga-
     nization (MISMO) naming conventions and end with a MISMO class word to indicate the category of data
     to which the term name belongs.
2	
     GSE-specific data points are required for all loan delivery transactions when a defined business condition
     exists. These conditions are not consistent for GSE delivery applications.




About the Authors
Ashish Shreni is the Consumer Lending Practice Head with Cognizant Business Consulting and has
worked for over 12 years in the banking, brokerage and insurance space on projects spanning business
and IT strategy, business process optimization and complex project execution. He can be reached at
Ashish.Shreni@cognizant.com.

Avishek Bimal is Consulting Manager with Cognizant Business Consulting, and has worked for over 12
years with leading banks across project management, business process optimization and consulting. He
can be reached at Avishek.Bimal@cognizant.com.




About Cognizant
Cognizant (NASDAQ: CTSH) is a leading provider of information technology, consulting, and business process out-
sourcing services, dedicated to helping the world’s leading companies build stronger businesses. Headquartered in
Teaneck, New Jersey (U.S.), Cognizant combines a passion for client satisfaction, technology innovation, deep industry
and business process expertise, and a global, collaborative workforce that embodies the future of work. With over 50
delivery centers worldwide and approximately 137,700 employees as of December 31, 2011, Cognizant is a member of
the NASDAQ-100, the S&P 500, the Forbes Global 2000, and the Fortune 500 and is ranked among the top performing
and fastest growing companies in the world. Visit us online at www.cognizant.com or follow us on Twitter: Cognizant.




                                         World Headquarters                  European Headquarters                 India Operations Headquarters
                                         500 Frank W. Burr Blvd.             1 Kingdom Street                      #5/535, Old Mahabalipuram Road
                                         Teaneck, NJ 07666 USA               Paddington Central                    Okkiyam Pettai, Thoraipakkam
                                         Phone: +1 201 801 0233              London W2 6BD                         Chennai, 600 096 India
                                         Fax: +1 201 801 0243                Phone: +44 (0) 20 7297 7600           Phone: +91 (0) 44 4209 6000
                                         Toll Free: +1 888 937 3277          Fax: +44 (0) 20 7121 0102             Fax: +91 (0) 44 4209 6060
                                         Email: inquiry@cognizant.com        Email: infouk@cognizant.com           Email: inquiryindia@cognizant.com


©
­­ Copyright 2012, Cognizant. All rights reserved. No part of this document may be reproduced, stored in a retrieval system, transmitted in any form or by any
means, electronic, mechanical, photocopying, recording, or otherwise, without the express written permission from Cognizant. The information contained herein is
subject to change without notice. All other trademarks mentioned herein are the property of their respective owners.

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GSE Loan Delivery: Interim Analysis and Approach

  • 1. • Cognizant 20-20 Insights GSE Loan Delivery: Interim Analysis and Approach Executive Summary benefits of the UMDP program, as well as the implementation challenges faced by players While the recent housing crisis can be attributed across the mortgage industry. It concludes with to a number of factors — low interest rates, exotic an approach for deploying business and techno- products, lack of audit controls, inadequate logical improvements that can reduce risk and credit risk analysis, insatiable investor appetite, optimize the entire loan origination process. predatory lending and irresponsible borrowers — one of the key factors was the non-availability UMDP Program Overview of consistent, accurate and detailed origination The GSEs announced the launch of UMDP on May data. This problem has led to inadequate consid- 24, 2010, under the directive of the FHFA. UMDP is eration/evaluation of several of the factors stated aimed at helping organizations implement uniform above. appraisal and loan delivery data standards, which Government Sponsored Enterprises (GSEs), would facilitate data accuracy and integration of Fannie Mae and Freddie Mac, created the Uniform mortgage data across the industry landscape. As Mortgage Data Program (UMDP) at the direction depicted in Figure 1, this program comprises three of the U.S. Federal Housing Finance Agency components. (FHFA). UMDP aims at significantly improving the While the technical requirements and specifica- depth, breadth and quality of data throughout tion for UAD and UCDP are identical, the ULDD the mortgage life cycle to promote transpar- requirements are not consistent for both GSEs ency, accountability, compliance and better risk in the case of conditionally independent2 data management. This white paper discusses the points. UMDP at a Glance Component Objectives Data Elements Uniform Appraisal Improving data quality by having uniform 209 data points.1 Dataset (UAD) standards for capturing appraisal data. Uniform Loan Improving data quality by having uniform Over 600 data points, approximately Delivery Dataset standards for capturing loan delivery data. half to be implemented in Phase l and (ULDD) the rest over time. Uniform Collateral Facilitating electronic submission of UAD includes all the data points Data Portal (UCDP) appraisal data files to the GSEs through the required to complete the appraisal uniform residential appraisal report form. report form. Figure 1 cognizant 20-20 insights | april 2012
  • 2. A Step in the Right Direction • LOS vendors: Numerous banks have installed these platforms to originate thousands of UMDP represents an attempt to address the loans per month. LOS vendors will be the key various data issues plaguing the industry. drivers of ULDD implementation as they will Supported by UMDP, the breadth and depth of need to enhance and roll out their products loan data — delivered on a timely basis through across several banks. a common industry standard — will lead to signifi- cant improvements in transparency for investors, • Originators: These companies have the as well as strengthen risk management capa- ultimate responsibility to be ULDD compliant bilities, lender accountability, secondary market as they will be responsible for submitting loans pricing and reporting/analytics. This initiative in prescribed format to the GSEs. will not only lay out the foundation for future controls, but also be essential in bringing back • GSEs: These organizations will need to enhance several internal systems to incorpo- investors to the secondary market. rate enhanced data into their existing pooling, pricing, trading, investor reporting and Timelines and Impact Analysis analytics systems. The GSEs have laid down specific timelines to implement the components of UMDP, which • Third-Party Service Providers: Appraisal management companies will need to start starts with implementation of UAD by September providing data in the required format to origi- 1, 2011, to implementing ULDD by November 2012. nators through their existing delivery channels Key timelines and impact analysis on key players and will need to enhance their delivery channels is summarized in Figure 2. Key participants to provide adequate data depth and breadth impacted will be loan origination system (LOS) per UMDP. They will also need to update forms product vendors, originators, GSEs, third-party for their vendor network that actually process service providers, rating agencies, investors and the orders. servicers. ULDD Transition Timeline Sept. 1, 2011 Dec. 1, 2011 March 19, 2012 July 23, 2012 November 2012 UAD ULDD UCDP ULDD ULDD All appraisers must All loans with application Appraisal report must be Loans with an application All loan deliveries on or after complete the appropriate received dates on or after this submitted to the UCDP if: received date on or after this date must include the appraisal forms as date must include the applicable The loan application is December 1, 2011, that are two additional data points required by the UAD. ULDD data points for Phase I. dated on or after delivered to either GSE on or required by the SEC. December 1, 2011, and after July 23, 2012, (previously UCDP The exact date is yet to be For loans with application March 19, 2012) must meet the An appraisal report ULDD Phase I requirements. communicated. received dates on or after this is required. date, the appraisal report form, UCDP if required, must be submitted Doc File ID (ULDD data Doc File ID (ULDD data point to the UCDP prior to delivery, if point Appraisal Identifier) Appraisal Identifier) is the loans are delivered on or is not required at delivery required at delivery on or after March 19, 2012. until July 23, 2012. after July 23, 2012. IMPACT UAD ULDD UCDP ULDD ULDD Originators/LOS Vendors Originators/LOS Vendors Originators/LOS Vendors Originators/LOS Vendors Originators/LOS Vendors Enhance systems and Enhance systems and prepare Enhance systems and Enhance systems and Enhance systems and prepare staff to support staff to support and process prepare staff to make prepare staff to support prepare staff to support and process new UAD data per ULDD. final preparations for and process data per and process data per final compliant forms. Third-party Servicers mandatory delivery of ULDD. ULDD requirements. Third-party Servicers Enhance systems and prepare appraisal forms through Final preparations for the Third-party Servicers Enhance systems/forms staff to support ULDD. the implementation delivery of ULDD Phase I Ensure that they provide and train vendors/staff of the UCDP. loan data. the required data elements GSE on using the new Enhance several internal Ensure users are to lenders required per SEC. configured in UCDP. UCDP appraisal form. systems to move from current Originators/Third-party Servicers data breadth and format to Servicers Enhance systems to process new standards. loans with enhanced data Upload appraisals to the UCDP requirements and investor UCDP, working with Originators/LOS Vendors reporting. vendor if applicable, to Enhance systems and prepare capture and store the Rating Agencies/Investors staff to support and process Appraisal Identifier data Enhance pricing models data per ULDD. point (DocFileID) for (data and logic) to include Third-party Servicers delivery with the ULDD. enhanced factors in price Enhance systems and prepare determination. staff to support ULDD. Figure 2 cognizant 20-20 insights 2
  • 3. • Rating Agencies/Investors: Both will need to access controls and accountability for each enhance their pricing models in terms of data field. This will be a challenging task given and logic to include enhanced factors in price the fact that detailed analysis of hundreds of determination. screens, scores of roles and hundreds of fields will be required to achieve this along with cor- • Servicers:These companies will need to responding validations. prepare for boarding and managing loans with enhanced data requirements as well as • Training and Change Management: Given enhanced and consistent investor reporting. the number of parties involved and extent of changes required, training the staff to adapt Implementation Challenges new fields will be a difficult habit to break. ULDD implementation across various systems Analyzing the impacts on business processes and stakeholders is not without challenges. The and swiftly aligning them to go in hand with the challenges include multiple parties and stake- changes might turn out to be another compli- holders with conflicting priorities, extensive cation during the implementation. customizations, multiple installations, training and change management, coordination and • Changes to Data Warehouse Infrastructure: embracing a unified view of these changes. Any changes to the source systems will have Specific challenges include: a corresponding impact on the DW. Originators should implement the changes to the DW along • Multiple Parties and Stakeholders: Successful with the source systems to avoid inaccuracies and timely implementation of UMDP is in the reports generated and analysis done possible only through seamless coordination with the data in the DW. between various stakeholders — originators, LOS vendors, third-party service providers • Tight Data Dictionary and Edit Checks: The GSEs have published a very tight data and various units within these entities (IT, dictionary for loan delivery with several business, data warehousing (DW), etc.). Given business rules at field level. The XML file will be the different priorities of these stakeholders rejected if the supplied data does not meet the and their business units, this is easier said than specified guidelines. This would lead to extra done. programming effort in terms of building these • Product vs. Client-specific Requirements rules up front into the LOS, as well as checking and Customizations: LOS vendors and origina- prior to loan delivery. Exception reports and tors are struggling with identifying, managing exception analysis and remediation teams may and implementing changes to their disparate be required for an initial period to overcome versions of systems, as considerable custom these challenges. code has been added on top of base products. For some originators, particularly those that Suggested Approach use plain vanilla features, this change might be A solution approach to implement UMDP easier to make and manage, but for those that requirements comprises a unified plan and have customized the platform significantly, governance model across various stakeholders identifying and implementing changes will be and units within them, GSE data dictionary-driven difficult given the limited availability of LOS approach, and a deeper/long-term view of imple- vendors’ professional services teams. Updates mentation. As depicted in Figure 3, the approach to the customized origination products for a would start with the GSE data dictionary, identifi- variety of clients (as mandated by UMDP) are cation of data gaps, and a determination of how a daunting task for product vendors. Simul- to holistically fill these gaps, followed by an imple- taneously, product vendors will need to make mentation plan. Additionally, the implementation updates to their core products to facilitate new approach should be flexible and extensible to implementations in the future. conform to future enhancements with the imple- mentation of an extensible business rule engine • Simple Field Additions Will Not Help; to check and compare each data element against Role-based Access and Accountability Is documents (images/PDFs) and data point source Required: LOS vendors and originators who system information to ensure data accuracy and view this simplistically (i.e., just add the fields) consistency. An effective audit trail should be will not be able to take true advantage of this generated to track the prefunding reviews and opportunity if they do not take into account cognizant 20-20 insights 3
  • 4. An End-to-End UMDP Implementation Plan Data Gap to Business Identify Data Gaps Function/Role/Screen Mapping Define and Prioritize • GSE data dictionary is the • Map each data gap to business • Sound change management starting point. process/function and role. practices to enhance systems and • Map current data set to • Map each gap to various applications; business process to capture data. GSE data dictionary. start upstream and traverse • Implement through unified • Identify gaps — data/depth. downstream. governance model. • Define business rules for each data element. • Define document, field and system mappings for comparison. Figure 3 Data Sources Master Data changes to reduce buy-back requests from the Transform Edit Checks Conclusion GSEs/investors (see Figure 3). • Consolidate all data in • Maintain in enterprise UMDP is a data to in the •rightcomparison across bring • Transform step Data direction to single DW for effective data definition and As with data submission guidelines for various transparency and accountability among various UMDP standards. system and documents. control & distribution control repository. • Check data rules before loss (Sources will beprograms on • Transform & mitigation LOS, POS, the servicing side - stakeholders. UMDP not only provides trans- submitting. Lead, CRM etc.). parency and accountability butmanagement the standardize data. Home Affordable Modifications Program (HAMP) • Exception also lays • Up-front implementation • Source of truth across & resolution. foundation for possible restart of the secondary and of rules inAffordability Foreclosure Alternative Home source apps to the enterprise. • Submit to GSEs. capture the data points (HAFA) — the datarules loan market. Delivering high-quality data to through business dictionary for UMDP is equally tight and could be a cause for concern. These engine. investors in a consistent and timely manner will constraints should be handled at the LOS appli- allow investors and rating agencies to effectively cation and data submission/DW stage by building evaluate, rate and manage risk associated with the rules up front in the application as well as mortgage investments. downstream (prior to submission). Originations While UMDP will require up-front investment from IT/DW should take guidance from their servicing various participants such as lenders, vendors, counterparts who have already implemented servicers, investors and rating agencies, in the a process very similar to UMDP for various long run all parties will benefit from improved data government programs. As depicted in Figure 4, quality and transparency and business processes the ideal architecture should comprise data con- enabled by a technology refresh and resultant solidation and standardization across sources, new business opportunities. This industry-wide Data Gap to Business transformation, Data Gaps Identify edit checks and corresponding Function/Role/Screen Mappinglead to a moreand Prioritize efficient, effort will Define transparent, exception management and submission. This consistent and streamlined operations and risk would GSE data dictionary is the • provide a single source for data definition gap to business • Map each data • Sound change management starting point. process/function and management for all industry participants. Loans role. practices to enhance systems and management (e.g., set to definition • Map each gap to various applications; data repository), • Map current data supported by UMDP will fostercapture data. business process to an environment accessGSE datadistribution across the start upstream and traverse and dictionary. enterprise, • Implement through unified downstream. of trust leading governance model. to improved participation in the while•taking into — data/depth. UMDP requirements. Identify gaps account the • Define business rules secondary market. for each data element. • Define document, field and system mappings for comparison. UMDP Implementation Data Flow Data Sources Master Data Transform Edit Checks • Consolidate all data in • Maintain in enterprise • Transform data to • Data comparison across single DW for effective data definition and UMDP standards. system and documents. control & distribution control repository. • Check data rules before (Sources will be LOS, POS, • Transform & submitting. Lead, CRM etc.). standardize data. • Exception management • Up-front implementation • Source of truth across & resolution. of rules in source apps to the enterprise. capture the data points • Submit to GSEs. through business rules engine. Figure 4 cognizant 20-20 insights 4
  • 5. Footnotes 1 A “data point” is the term name that must comply with Mortgage Industry Standards Maintenance Orga- nization (MISMO) naming conventions and end with a MISMO class word to indicate the category of data to which the term name belongs. 2 GSE-specific data points are required for all loan delivery transactions when a defined business condition exists. These conditions are not consistent for GSE delivery applications. About the Authors Ashish Shreni is the Consumer Lending Practice Head with Cognizant Business Consulting and has worked for over 12 years in the banking, brokerage and insurance space on projects spanning business and IT strategy, business process optimization and complex project execution. He can be reached at Ashish.Shreni@cognizant.com. Avishek Bimal is Consulting Manager with Cognizant Business Consulting, and has worked for over 12 years with leading banks across project management, business process optimization and consulting. He can be reached at Avishek.Bimal@cognizant.com. About Cognizant Cognizant (NASDAQ: CTSH) is a leading provider of information technology, consulting, and business process out- sourcing services, dedicated to helping the world’s leading companies build stronger businesses. Headquartered in Teaneck, New Jersey (U.S.), Cognizant combines a passion for client satisfaction, technology innovation, deep industry and business process expertise, and a global, collaborative workforce that embodies the future of work. With over 50 delivery centers worldwide and approximately 137,700 employees as of December 31, 2011, Cognizant is a member of the NASDAQ-100, the S&P 500, the Forbes Global 2000, and the Fortune 500 and is ranked among the top performing and fastest growing companies in the world. Visit us online at www.cognizant.com or follow us on Twitter: Cognizant. World Headquarters European Headquarters India Operations Headquarters 500 Frank W. Burr Blvd. 1 Kingdom Street #5/535, Old Mahabalipuram Road Teaneck, NJ 07666 USA Paddington Central Okkiyam Pettai, Thoraipakkam Phone: +1 201 801 0233 London W2 6BD Chennai, 600 096 India Fax: +1 201 801 0243 Phone: +44 (0) 20 7297 7600 Phone: +91 (0) 44 4209 6000 Toll Free: +1 888 937 3277 Fax: +44 (0) 20 7121 0102 Fax: +91 (0) 44 4209 6060 Email: inquiry@cognizant.com Email: infouk@cognizant.com Email: inquiryindia@cognizant.com © ­­ Copyright 2012, Cognizant. All rights reserved. No part of this document may be reproduced, stored in a retrieval system, transmitted in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise, without the express written permission from Cognizant. The information contained herein is subject to change without notice. All other trademarks mentioned herein are the property of their respective owners.