Most of you have likely received an email bulletin from the CFPB HMDA Help regarding data issues in reporting the Street Address Field. It’s important to note this is regarding errors in the Street Address field only and not in other fields such as City/State/Zip and has nothing to do with geocoding the Census Tract. We have obtained further clarification from the CFPB on this communication.
Subject: RE: HMDA Data Outreach: Review Data for Invalid Entries in the Street Address Field
Hello, Thank you for reaching out for clarification! This email went out to several financial institutions that had data flagged when we ran an analysis on the Street Address field. The brief that was attached to the original email describes the types of issues that were discovered. Please use the examples of errors in the brief to review your data and resubmit if needed. We are unable to support an individual file review. Note that there is a chance that the analysis may have flagged data that is accurate resulting in false positives. If you have reviewed your data and found it to be accurate, no action is needed.
Thank you,
CFPB HMDA
If you have validated your HMDA data and are confident in the accuracy of the data submitted, as stated in the above response from the CFPB “no action is needed.” If you choose to review your data based on the guidance provided in the CFPB’s letter and you find an “invalid” address, TCA recommends you discuss refiling your LAR with your Senior Management and consider reaching out to your examiners for additional guidance. Any specific questions should be directed to the CFPB HMDA Help team.
TCA will be monitoring for additional information and clarification from the Bureau on this topic and provide additional information when it becomes available.
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