I've got two related questions:

1. What do you report as the city for HMDA purposes if the city/town name used in the USPS address doesn't exist?

For example, in Maine there is a zip code for Cape Neddick, which is a neighborhood within the town of York. Cape Neddick isn't an organized municipal entity of any kind (Maine doesn't have official villages within towns or anything like that). To comply with the official interpretations of Paragraph 4(a)(9)(i), we'd report the property as being in the town of York, but would report the zip code that the USPS considers to be Cape Neddick. I'd like to know if that's what you're doing in this situation, or if you are reporting the town name used in the USPS address even though that isn't an actual city/town.

2. Can the city/town listed in the property address on the note and mortgage differ from the city reported on the HMDA LAR?

Some investors are now saying that we must use the USPS address as the property address on the note and mortgage, even if the USPS address uses a town name that doesn't exist. I'd previously read the official interpretations to mean that we needed to use the actual city/town in the property address on the note/mortgage. Looking at it again, I'm wondering if there might be some flexibility there, as the requirement that the reported address "correspond to the property identified" on the note/mortgage does not necessarily mean "match the property address" on the note/mortgage. If we consider the Exhibit A property description as identifying the property instead of the property address, that would allow us to use the USPS address as the property address on the note/mortgage while still complying with the official interpretations. Using the example in the first question, we'd be able to report that the city was York because that matches up with the Exhibit A description, even if the property address on the note/mortgage said Cape Neddick. What do people think about that interpretation?

Thanks in advance for your perspectives.