We received the following message today from the HMDA Help Desk. We use a well-known vendor and all data is checked before submission. Did anyone else receive this message?

The HMDA Operations team routinely analyzes data submitted to maintain data integrity and ensure accurate reporting. During our review of 2020, 2021 and 2022 data, we identified that your HMDA Loan/Application Register (LAR) data may contain invalid entries in Data Field 13: Street Address.
Data were flagged during our analysis for several reasons, including but not limited to multiple addresses, multiple property numbers, missing street names, placeholder addresses (e.g., TBD Condo or 000 Street), information that should be listed in other fields (e.g., zip codes), or listing the street intersection . The attached brief provides details on the type of errors we encountered in our analysis.
Page 61 of the 2022 Filing Instructions Guide details how to format the Street Address field. Excerpt below:
Street Address: Enter the street address of the property as one (1) data field. 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. Address components include, as applicable, the following individual items:
1. Primary Address Number
2. Predirectional
3. Street Name
4. Prefix
5. Suffix
6. Postdirectional
7. Secondary Address Identifier, such as apartment
8. Secondary Address, such as apartment number

An example of a valid Street Address is “456 W Somewhere Ave Apt 201”. Including address components that are not included in the above list may indicate an invalid Street Address. When the property address is not yet known, the Street Address field can be reported as NA. Comments 4(a)(9)-1 and -2 to Regulation C, 12 CFR Part 1003, provide additional context on how to appropriately report a street address if a covered loan is related to more than one property.
We encourage a review of your HMDA filing(s) for adherence to Regulation C requirements and Filing Instructions Guide guidance. If you would like to review or update your HMDA data, the HMDA Platform is open for resubmission for 2020, 2021 and 2022 data here: HMDA Filing Platform. Resubmission of data will not change the timeliness status of the original HMDA filing.
The HMDA Operations team will conduct another analysis on data (including resubmissions) on May 15, 2023 to determine how many suspected invalid Street Address entries still remain in the LAR data.
Please reach out to HMDAHelp@cfpb.gov with any questions.

I didn't receive it, but i have some correspondence from my HMDA consulting firm (Key Compliance) that a lot of banks are receiving the message (that's an exempt field for my bank anyway...i guess that's why i didn't receive it). I'm copying below the answer that the CFPB gave in response to what to do with the message.



“Thank you for reaching out for clarification! This email went out to several financial institutions that had data flagged when we ran an analysis on the Street Address field. The brief that was attached to the original email describes the types of issues that were discovered. Please use the examples of errors in the brief to review your data and resubmit if needed. We are unable to support an individual file review. Note that there is a chance that the analysis may have flagged data that is accurate resulting in false positives. If you have reviewed your data and found it to be accurate, no action is needed.“

Pretty crazy if you ask me. The street address does not appear in the modified LAR and I'm sure all of our loans are geocoded correctly - we are very careful about this. I don't know why they are asking institutions to do this. I can see it if there are numerous errors - we just don't have the staffing to look at three years worth of data.

A lot of lenders received this message. This is not an error checked by the HMDA edit checks, but some vendors do have checks for it. The problem, as noted in the CFPB message, is that the available checks tend to through false positives.

I got the same. We verify all street addresses (under 1,000 LAR lines) manually with USPS. I sent a response asking for the specific lines that were identified with clarity that we do run every single address through USPS zip+4 website.

In our rural area, some addresses do not validate with zip+4. We got an acknowledgment that we had contacted CFPB though with this thread being established, I'm less inclined to deep dive given my compliance process and see what happens to my response and/or after May 15.

I can support every field answer I reported from my sheets, files, and LAR.

Unless anyone else on this thread has an additional idea as to how I should react.

If they do the same thing after May 15, nothing will change then. So doing nothing will likely result in them sending the same message.

Regardless, even if there is some odd thing going on in the street address field, we are confident that our loans are geocoded correctly. My point being that making a minor changes will not result in a change to the geocoded result.

We received it for our data submitted 2020, 2021, 2022 and have reviewed our address lines. We have periods, commas, pound signs and the information shown and received from CFPB and the FIG has none of those. We reached out to our vendor and asked why they didn't flag as a quality control issue prior to submission. Now we have to manually go back and make those corrections and resubmit. We are not happy with the vendor.

I'm a little confused why they need this data so standardized. Address isn't even a key field. What is it being used for? Only thing I can think is that they re-geocoding to the block level?

We have a lot of Construction-Perm loans that close before an address is obtained, and we use lot number or just street name or whatever we have on a document. I'm not sure what help it is to exclude this information from our LAR. Makes it a little confusing (and harder to scrub) to have a geocode with an NA address. They really need to be more clear about what they want before telling people to dig through 3 years of data for what seem like pretty minor meaningless data issues. If there's a real issue then let us know what it is. I'm inclined not to waste my time digging through and resubmitting unless they give a real reason.

I had asked them for more clarity on how they identified me as having issues and got the following response:


Don't know if that helps anyone else but based on how we validate our data, I'm not planning to touch anything unless/until I get told my data was rong.

I responded to say:

To Whom It May Concern,
We use a well-known vendor to submit our data and have contacted them regarding this matter. The vendor system complies with the Filing Instructions Guide, therefore, we can only assume that any data flagged during your review is a false positive.
If you have detailed information specific to our bank regarding any errors, then please provide.

We also received the same message asking us to review 2020, 2021, and 2022.

BSA, it wasn't asking you to review. It was alerting you that you might want to review but there is no regulatory change or mandate to comply with the email. In fact, ABA has come out with information that stated:

First, this is not a regulatory demand, but rather a red flag raised by the CFPB’s HMDA Operations team after, as they call it, a “routine analysis” As odd as the note may be—it does not carry a threat of enforcement, but rather, it advises about potential errors in the institution’s filing. Note the underlined language (see above) does not impose new action under new deadlines—it only suggests a possible error.

Second, the CFPB’s HMDA Help department has sent the following explanation to inquirers—“Thank you for reaching out for clarification! This email went out to several financial institutions that had data flagged when we ran an analysis on the Street Address field. The brief that was attached to the original email describes the types of issues that were discovered. Please use the examples of errors in the brief to review your data and resubmit if needed. We are unable to support an individual file review. Note that there is a chance that the analysis may have flagged data that is accurate resulting in false positives. If you have reviewed your data and found it to be accurate, no action is needed.”

This explanatory note confirms that CFPB is only cautioning about possible errors—it is not confirming the presence of, nor accusing institutions of, a HMDA regulatory breach. In fact, the statement admits that there may be no mistake at all, and that no action may be needed.

Third, the CFPB affirmed that the filer has the ultimate say as to whether their data is correct and whether there is a need to resubmit. This leaves the decision to institutions and reinforces that there is no regulatory order that must be followed in light of this email.

It appears that this email is a badly executed “alert” of possible errors detected by the agency—the email did not intend to add substance to the rules or change regulatory timing elements. Also, given the high number of inquiries to CFPB regarding this issue, we are likely to see further agency pronouncements on this item.


You don't have to do anything. fwiw, I reviewed mine and found mostly periods (ex: St.) a few commas and &. We pull USPS on every file (and keep it in the file) so all I've done is alert my staff to not use any of them going forward. I'm sure CFPB will not be coming after any of us.

We've done the same as Truffle. I found one & symbol and two # symbols. The & we shouldn't have used, but not sure about the #. Is there anywhere that says you can't have an # symbol?

Anyway, the only other thing I'm seeing is that sometimes we will fully spell out street or drive or avenue instead of abbreviating. Is that an issue?

ComplyGuy:
From the USPS standards that were included in the data outreach email:

"The pound sign (#) should not be used as a secondary unit designator if the correct designation, such as APT or STE, is known or is shown in the ZIP+4 file."

"If the pound sign (#) is used, there must be a space between the pound sign and the secondary number."

https://pe.usps.com/text/pub28/28c2_003.htm

For suffixes, USPS prefers abbreviations, but full spelling is acceptable.

https://pe.usps.com/text/pub28/28c2_015.htm

Awesome, thank you!

We have a few applications with a street name, but no street number (e.g. new construction). Should we change the street address to "NA" and resubmit?

We will be re-submitting to correct errors like that. We found a few exactly like that where only the street name was recorded. We also found a few that did not include the complete street name (e.g., "123 Anywhere Dr" where "Dr" was missing) or that listed a Lot Number instead of a street address that will also be corrected.

So, if no street number was assigned to the property, the address field should be NA, but we still report all the geocodes?

I am finding a mixture of new construction and preexisting homes where there are no street numbers or a mobile home where we know the location it is being put, but there was not a street number assigned yet. Our pile is very small of loans like this, but I want to make sure I am interpreting this correctly before resubmitting. It feels so awkward to report NA when we know the exact location, just not the street number.