Storage Upgrade Rescues Mortgage Lender from Compliance Data Glut

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    September 1

Mortgage lenders face heavier reporting and record retention requirements that call for more data to be stored for longer durations. To defray expense and server space, lenders are increasingly looking to emerging storage technology. Case in point: new storage technology implemented at Fairway Independent Mortgage. 

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“Our data retention requirements have exploded in the past year,” says Randy Allen, vice president of enterprise infrastructure for Fairway, a $3.9 billion national lender based in Plano, Tex. Allen says the company’s data footprint has expanded from eight terabytes to 48 terabytes in that short period. He attributes the bloat to regulatory mandates and the impact of the lender’s paperless lending project, which has automated the flow and storage of more borrower and loan information.

To respond, Fairway has migrated to a new storage solution that Allen expects will save the company hundreds of thousands of dollars in data storage costs over the next year or so, while vastly enhancing capacity and flexibility over its prior network of 30 physical on-site severs. “It allows us to virtualize our physical infrastructure and scale out as needed,” Allen says, adding the ongoing project also aids in backup for continuity.

The lender has built a new internal data storage system with the use of Dell EqualLogic and Dell Compellent storage area networks. EqualLogic and Compellent both provide some virtualized storage management automated tiered storage, thin provisioning (which allocates storage resources based on timely need rather than calculating total necessary volume) and replication. EqualLogic provides hierarchical storage management. Compellent provides data replication.

Storage can be customized based on the lender’s business rules. Fairway determines what kinds of data should be assigned to specific arrays based on the importance of the information included in that data set, or how often that data is accessed. The high-tiered data shows up faster in searches. The more expensive and “faster” storage arrays are set aside for vital and time-sensitive information, while less expensive, “slower” arrays are for data that the lender is required to store, but in all likelihood won’t have to access “on the spot.”

The lender reserves tier one data for email and database access, for example, with data archiving and post-closing information relegated to lower tiered storage. The lender uses SAS (serial attached SCSI) storage arrays for top tiers, and SATA (serial advanced technology attachment) arrays for low tiered storage. Allen says the cost for SAS SCSI drives, which are much faster, are about three times that of SATA drives ($150 vs $450 for a similar sized purchase).  

“You can use inexpensive storage for most data,” Allen says. “Why would you put archived loans that have not been touched in six months on expensive disk arrays?”

The lender is also upgrading its disaster recovery setup. Previously, a backup disk was used to restore the lender’s service to a specific moment in time (the time of the last “back up”). Backing up an image of the virtual server allows continuous updates, with availability in minutes. “We can now build out a true business recovery plan, where our virtual infrastructure is replicated in real time,” Allen says.

The number of regulations that Fairway and all mortgage lenders face is growing rapidly. In the wake of the credit crisis of the past few years, mortgage lenders are required to follow new credit risk reporting and compliance mandates that mandate storage of more data cataloguing lenders’ credit and lending activities. Additionally, this data needs to be held for longer periods. 

There are also a wide variety of rules for information storage and reporting which are being strengthened over time. To help lenders keep tabs, the National Association of Mortgage Brokers has issued guidance for such requirements under The Equal Credit Opportunity Act, Gramm Leach Bliley, and Fair Credit Reporting Act.

Also, a recent Federal Reserve proposal could expand record retention requirements under the Dodd-Frank law, the Truth in Lending Act (TILA) and Regulation Z. TILA currently requires creditors to retain evidence of compliance for two years after disclosures have been made. Dodd-Frank extends the statute of limitations for civil liability for a violation of the prepayment penalty provisions or ability-to-repay provisions to three years. The proposed Fed changes would lengthen the record retention requirement of Regulation Z to three years to match the Dodd-Frank standard.

Bernard Golden, CEO of Hyperstratus, a cloud computing consultant, says strategies such as data deduplication or server virtualization can help manage the growth in data storage requirement posed by these regulations, which aren’t going to go away.

"A lot of people are starting to wake up to this scale issue. It's not a one-time thing. It's going to be 70 percent a year growth for the foreseeable future," Golden says. “You have to find a way to change storage. The old way won’t scale."


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