For nonbank lenders, BNPL and earned-wage-access providers
Ten, thirty or fifty state licences each ask for a report. An examiner, an attorney general or an auditor then asks where a number came from. We keep the answer with the figure.
What we heard
The reporting calendar
The exam, the AG, the auditor
The gap
The reports still go out. What is missing is the derivation: which rows, which transformation, which rule, who signed the interpretation — so the next question can be answered from the pack.
Our core principle
What we will not do. File on your behalf, decide whether a product is covered by a rule, or give legal advice. Whether a loan is a covered credit transaction, and whether you or a partner bank is the covered institution, are questions for counsel. We show what the data says and which line it maps to; we do not say you are compliant.
Step 1 · map once
| Your tables (examples) | Mapped to | Used for |
|---|---|---|
| applications, decisions | Applications by outcome and geography | HMDA LAR, MCR application data |
| loans, servicing_events | Originations, balances, delinquency | MCR financial and servicing sections, state annual reports |
| borrowers, properties | Demographic and property fields | HMDA data points |
| licenses, states | Licence footprint | which report, which state, which deadline |
| advances, repayments (EWA) | Advance volumes and fees | state EWA reports |
Mappings are reviewable definitions a named person confirms. When the LOS or the servicing system changes, we update the map, not the report.
Step 2 · the flow
Step 01
Step 02
Step 03
Step 04
Step 05
Rulebooks and elections
The federal calendar is read and recorded. State-specific report content for lending regimes is not yet modelled; each state's own text is confirmed before a figure is built on it.
Quarterly, within 45 days of the end of the calendar quarter; Form Version 7 from the first quarter of 2026.
NMLS — NMLS Mortgage Call Report Form Version 7 User Guide (US)
Annual filing from 1 January to 1 March; quarterly for institutions with 60,000 or more applications and covered loans.
FFIEC / CFPB — FFIEC HMDA Platform — data collection timelines (US)
Effective 30 June 2026; compliance 1 January 2028 for lenders with 1,000 or more covered originations in each of two consecutive years; first submission 1 June 2029.
CFPB — Small Business Lending Under the Equal Credit Opportunity Act (Regulation B), final rule, 91 FR 23530 (May 1, 2026), FR Doc. 2026-08494 (US)
Per state; content and deadlines confirmed from each state's enacted text before modelling.
No regime verified for this item — the first question we ask.
What we look for
Where the figures go wrong — each one becomes a check with a derivation.
| Pattern | What it looks like in the data |
|---|---|
| Conversion mis-mapping | Transaction codes mapped to the wrong GL account after a servicing migration; balances that reconcile only by hand. |
| Acquired books | A purchased portfolio or an acquired lender with its own codes, folded into one report. |
| Covered or not | Which originations count toward a threshold, and whether a partner bank is the originator — recorded as an election, not assumed. |
| State scope | The same loan reported to several states under different definitions of in-state. |
Step 3 · the output
Short sentences instead of query output. Every figure links back to the rows in your warehouse that produced it, the rule it maps to, and the person who signed the interpretation.
Step 4 · your team decides
Chief Compliance Officer
Head of Reporting, with data
General Counsel
CCO or CFO
Nothing reaches a regulator or an authority without human approval. Every release records who asked, what was shared, who approved it, and when.
Security and control
Proposed pilot
How we will measure it
Pilot terms: the pilot fee is credited against a first year signed within 30 days. Every pack carries its own caveats on its cover; nothing is suppressed to make a figure look cleaner.
Talk to us
If this is on your desk, tell us what you are dealing with and we will reply within one to two business days.