In prior years, the IRS would be generated by FFIEC, and they' d ask me to confirm that we have branches in every MSA listed. If we had made loans that geocoded to Memphis, for instance, then Memphis would show up on the IRS. (We geocode all loans, not just the ones in our MSA). We'd have to say "No" on several rows, then send it back to FFIEC, then they'd send me a new IRS with only our branch MSAs listed. I'd sign that and return it, and that would end the submission process.

CFPB seems to be skipping some steps. They say, "Here's your IRS, it has 15 MSAs on it even though you only operate in 4 MSAs, and your choices are A) e-sign that the IRS is correct, or B) upload a different LAR that will cause a different IRS to generate.

What do I do? I emailed CFPB yesterday; no reply yet, of course. I'd be happy to wait 3 business days for them to respond (no I wouldn't) but I have other entities for which I have to proceed with filing their LARs too.

Maybe I missed something, but I read it to say "here's the MSAs you made loans in - are they correct?" I said yes and filed. We geocode all of our loans, too, not just the ones in our branch MSAs.

I'm with Becca...even obsure one-off in some random MSA where we have no branch still ends up on the report.

Ditto.

OP here: If that's what you've been doing for 2016 and prior, I'm 90% sure you've been doing it wrong. We used to get a Q595 report and answer "Yes/No" to "Do you have a branch in this location?" for every location reported; also the HMDA cover pages from the FFIEC said you had to either answer the Q595 or make notes to them on the Institution Register Summary to make it reflect your branch listing. But it's correct for 2017. CFPB's HMDA Help responded by email:

The logic and requirements for the IRS Report have changed in the current filing period. It now includes all MSAs for which a loan was reported in your LAR file, rather than only the MSAs in which your institution has a home or branch office. As a result, there is no longer a requirement for an institution to provide or validate a list of MSAs in which the institution has a home or branch office as part of the LAR submission.

If the report correctly reflects the loans reported in your LAR, you can proceed with the submission step.

Thank you for that answer - I was sweating it also!!