Thread Options
#1531084 - 04/04/11 03:40 PM Center of Zip
JUST CALL ME CRA Offline
100 Club
Joined: Aug 2002
Posts: 133
SOMEWHERE
We lend in a lot of rural areas and many addresses are rural routes which are not shown when you look them up on the FFIEC website. Is using center of zip accceptable in those circumstances or should we be finding a different source to geocode?
_________________________
Opinions do not reflect opinion of employer and cannot be relied upon as advise.

Return to Top
HMDA

   
HMDA Academy
#1531086 - 04/04/11 03:43 PM Re: Center of Zip JUST CALL ME CRA
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
It is acceptable as an absolute last resort. The preferred step to take is to geocode a nearby intersection or locate it on a map and then find that spot (as close as possible) on the tract map (at FFIEC or other tract map).

If you an do a zip+4 for the centroid you will get much closer to the actual location.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1531088 - 04/04/11 03:46 PM Re: Center of Zip JUST CALL ME CRA
RR Becca Offline
Power Poster
RR Becca
Joined: Sep 2004
Posts: 5,245
out of the frying pan...
I use maps, plats, surveys, nearest major crossroads, and/or sometimes directions (i.e. 3 mi north of X Road, on left side of Hwy 32) to locate rural addresses and anything else that doesn't show up on the FFIEC geocoder. Then I match whatever that location source was to the FFIEC map and report the info from there.
_________________________
You call it ADD. I call it multi-tasking.

Return to Top
#1531106 - 04/04/11 04:07 PM Re: Center of Zip RR Becca
JUST CALL ME CRA Offline
100 Club
Joined: Aug 2002
Posts: 133
SOMEWHERE
So, you are saying that it is not acceptable as a matter of routine, only when nothing else can be found. Correct?
_________________________
Opinions do not reflect opinion of employer and cannot be relied upon as advise.

Return to Top
#1531109 - 04/04/11 04:13 PM Re: Center of Zip JUST CALL ME CRA
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Correct. You should make an effort to locate it on a map first.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1531145 - 04/04/11 05:13 PM Re: Center of Zip Kathleen O. Blanchard
SMQ, CRCM Offline
Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Start with the appraisal in your file, they should have it plotted on a map. Don't rely on the geocode on the appraisal, it is a good way to double check, but examiners won't let you slide if he got it wrong.

We also use MapQuest to help get an approximate location and then plot it out on FFIEC's map. It's amazing how often MapQuest has a location when FFIEC doesn't.
_________________________
NOLA is my Beach!

Return to Top
#1531319 - 04/04/11 08:46 PM Re: Center of Zip SMQ, CRCM
arye23 Offline
Gold Star
Joined: Mar 2011
Posts: 294
Originally Posted By: SoccerMomQueen
Start with the appraisal in your file, they should have it plotted on a map. Don't rely on the geocode on the appraisal, it is a good way to double check, but examiners won't let you slide if he got it wrong.

We also use MapQuest to help get an approximate location and then plot it out on FFIEC's map. It's amazing how often MapQuest has a location when FFIEC doesn't.


Very good method, SMQ. Used it in my bank, and recommended it to rural banks when doing exams. Mapquest map, overlayed (if that's a word) on FFIEC map, with geocode and demographic printout. You shouldn't be questioned too much on that.
_________________________
CRCM

Return to Top
#1531336 - 04/04/11 09:34 PM Re: Center of Zip arye23
KTMiteComply Offline
Power Poster
KTMiteComply
Joined: Jul 2007
Posts: 3,298
only if I want to....
I've also signed up for GEOCODE.com It's not really that expensive and has had most of the items that have been rural routes for me...just a thought. Like Soccermom said...it's amazing how many it has what FFIEC doesn't crazy
_________________________
Trust in the Lord with ALL your heart...Prov 3:5-6

Return to Top
#1531364 - 04/04/11 11:15 PM Re: Center of Zip arye23
J Hunt Offline
100 Club
Joined: Feb 2002
Posts: 132
Phoenix, AZ
Agree - use this method often [with Google maps, but not to quibble ;)] for agricultural areas in several states and it works well.
_________________________
CRCM/CAMS

Return to Top
#1531367 - 04/04/11 11:26 PM Re: Center of Zip KTMiteComply
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I use geocode.com regularly (for individual tough cases and to batch geocode). It is updated more frequently than the database behind the FFIEC site.

If you have a street address you can get a zip + 4 at usps.com and then geocode with that and get a pretty good result. Zip + 4 is much more exact than a regular zip.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1532145 - 04/06/11 04:50 PM Re: Center of Zip Kathleen O. Blanchard
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 765
Kathleen,

During our last CRA examination, the regulator wanted a "dump" of our last three years of HMDA and CRA submissions. From that, they did a file comparison to ensure the address was properly geocoded. The trouble was that it is quite possible that in 2007 we used the process you stated to locate the census tract of an address that was not yet on the FFIEC site. Two years later (2009) when the regulators completed their file comparison, those addresses from 2007 are now on the FFIEC site and may geocode differently from the best estimate in 2007. The result, is they wrote us up. At the time (2007) we did the best we could as the address was not on the FFIEC site.

How can we prevent this in the future or do we just lay down and let them run all over us?

Return to Top
#1532150 - 04/06/11 04:55 PM Re: Center of Zip Tennismom
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I would raise a stink that they were using current data to measure old data. Not right.

Not sure what size bank you are. If you submit, I would keep all records of how you geocoded and really push the issue that at the time the geocoding was completed, this was the best you could do and you cannot go back in time and get a "do over" now that the FFIEC site is updated. It is good to have a process to try other sources when FFIEC does not have an address.

If you are smaller and do NOT submit, and don't have too many loans, you could batch geocode all of the data for the exam period. Then just manually cleanup those that need further attention.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1532753 - 04/07/11 03:19 PM Re: Center of Zip Kathleen O. Blanchard
SMQ, CRCM Offline
Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Totally agree with Kathleen, state your case for best available at the time.

FFIEC also goes back to 2008 (see drop down box), maybe you could prove your point by trying some of the addresses that they have cited.
_________________________
NOLA is my Beach!

Return to Top
#1532761 - 04/07/11 03:25 PM Re: Center of Zip SMQ, CRCM
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I believe once an address is updated for the FFIEC site for location, it is there for all years. What changes by year are any differences in MSAs, etc. that might have been modified as happens from time to time.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1540498 - 04/25/11 11:08 PM Re: Center of Zip Kathleen O. Blanchard
Moman Offline
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
FFIEC is a moving target. During our last exam in 2010, our FDIC examiner pulled a list of loans I had geocoded through a major outside vendor. He ran the address on FFIEC and received a result. I ran the same address in my office, 2 floors above him and on 2 of about 10 loans in question, received different results. He may have put in the city, state and zip combo, I normally put in the street address and zip. Same address and zip in both instances, but different census tracts. We are printing off every FFIEC run and placing it in the loan files as proof we had when the loan was last outprocessed. That way we have something to point to in the file that is an "official" government result. Both of us just shook our heads!
Last edited by Moman; 04/25/11 11:10 PM.
Return to Top
#1540508 - 04/25/11 11:57 PM Re: Center of Zip Moman
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
In the past FFIEC was updated quarterly for new addresses. New/changed MSAs etc are added as those changes are announced. It is important to "prove" how you geocoded because a geocoding at a later date can provide a different result. Yours was right at a particular point in time.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1540538 - 04/26/11 05:38 AM Re: Center of Zip Kathleen O. Blanchard
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
I have also printed out the "Google" map with the address pinpointed, and the FFIEC map with the "pinpoint" manually drawn on the corresponding area and then the census tract number highlighted.

The problem these days is you have a lot of new examiners that simply do not understand the nuances of geocoding. Also, there are certain address in the New York area where I have found that placing a "dash" in the address gets you a completely different MSA/TRACT than if you leave that dash out. So you really have to push back on those geocode findings.

Of course we all know that sometimes you get an examiner that does not "appreciate" any hint of questioning their omniscience. That's when you know you are in for a miserable time.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#1540539 - 04/26/11 06:24 AM Re: Center of Zip Princess Romeo
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Yes, NY addresses are challenging. The dash is important in areas of Queens and other parts of NYC. It indicates a block.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top

Moderator:  SMQ, CRCM