In reviewing the recently published HMDA aggregate data, I noticed that there are several records in each of our assessment area MSAs that have state codes that do not correspond to the applicable MSA. For example, for the Fort Collins MSA 22660 (see below), under the State Code GA, FL, and IN are listed when CO is the correct code for this MSA. The county and census tracts correspond correctly to CO and the MSA. I looked up several of the LEI numbers and they appear to be non-depository lenders (mortgage lending companies) and credit unions. I haven't been able to find information regarding this practice of reporting a different state code not within the MSA due to these entity types. I'm working on comparing our loan data with aggregate lenders within our MSAs in CO. I'm unsure if it would be accurate to consider these lenders when we compare our bank to our peers within the applicable MSAs. Thank you.
The example below is the correct Fort Collins, CO MSA and other than state code the other fields are correct.
derived_msa-md state_code county_code census_tract
22660 GA 8069 8069001603
22660 FL 8069 8069002600
22660 IN 8069 8069001305