It seems that many financial institutions received an email from HMDAHelp at the CFPB entitled: HMDA Data Outreach: Review Data for Invalid Entries in the Street Address Field.
the email is confusing to say the least. Financial Institutions are encouraged to analyze the street address fields of their LARS for years 2020, 2021 & 2022. The email states that resubmission of data will not change the timeliness status of the original filing. The email says that U.S. Postal Service Publication 28, Sub-Sections 231–239, can be used as a guide for formatting the street address to help improve geocoding accuracy. The email also states that including address components that are not included in the list (Primary Address Number, Predirectional, Street Name, Prefix, Suffix, Postdirectional, Secondary Address Identifier, such as apartment, Secondary Address, such as apartment number) may indicate an invalid Street Address. Maybe I am misreading this but, it seems that they are not wanting any special characters in the street address field, period.
I guess I have two questions: Does the act of resubmitting HMDA data have the potential to affect the overall HMDA rating? Also, if there are special characters in the street address field but it can be proven that the geocoding is still correct ….. in the end – isn’t that what is important -the geocoding should be correct? I know every institution needs to make the best decision they can on this.
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