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#423432 - 09/15/05 08:20 PM HMDA ~ FFIEC vs. American Fact Finder
Anonymous
Unregistered

We manually research our reported geocoding information. During our review process we routinely research from a source that the original processor did not use. If the loan processor used the Census Bureau's American Fact Finder then the reviewer will look the address up from the FFIEC site and visa versa. We have discovered contradicting information. One site shows the property on the north side of the street & the other shows it on the south side. The street is the dividing line between census tract #'s. The property is, in fact, on the north side but FFIEC shows it on the south side. Do we document what AFF shows and report their results? or is FFIEC the final answer?

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#423433 - 09/15/05 09:04 PM Re: HMDA ~ FFIEC vs. American Fact Finder
grmasterb Offline
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grmasterb
Joined: Feb 2004
Posts: 1,249
Indiana
I think it depends on your examiner. Many OCC examiners use the geocode function in CRA Wiz. Whenever there's been a discrepancy between Wiz and FFIEC, however, we haven't been dinged, so long as we show that we're reporting what FFIEC determined and that we CONSISTENTLY use the FFIEC program for geocoding.

I think the examiners value consistency. I would suggest that you get all of your people to use the same geocoding software.

Since you utilize a manual review process, could you not also refer to the loan file's appraisal to better determine the exact location of the property (north or south side of street)? Many appraisals map where the property is located.

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#423434 - 09/15/05 09:54 PM Re: HMDA ~ FFIEC vs. American Fact Finder
#12 Offline
Diamond Poster
Joined: Jun 2005
Posts: 1,338
We have some properties that the FFIEC website puts totally in the wrong county! We just document the file clearly to show where the property is actually located.
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#423435 - 09/16/05 03:52 PM Re: HMDA ~ FFIEC vs. American Fact Finder
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
There are differences in programming between geocoding software. However the actually data used for geocoding by Am Fact Finder, Wiz and FFIEC comes from the same source.

Small differences occur due to one program not being updated exactly as the other. In some cases you may get an exact match on the address, and in others the geocoded is obtained by using the zip+4 code of the same address. This places a location in the center (centroid) of a 7 square block area. So if an address is close to a tract boundary the centroid can be on either side of the street.

As geocoding is not an exact science, as long as you can show you made a determined effort and if your geocode is close to anything the examiners come up with, they will accept it. Neither the the FFIEC or data in Wiz is the absolute gospel of geocoding.

I have been told by legal representatives of FFIEC that their geocoder was never intended to be the end all of geocoding. It was originally provided as an aid to look up more difficult addresses. Banks were supposed to use other geocoding resources (and pay for them) Obviously it hasn't worked out that way.
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#423436 - 09/16/05 06:59 PM Re: HMDA ~ FFIEC vs. American Fact Finder
Anonymous
Unregistered

I, personally, have never tried using the zip+4 but that sounds like a good idea for future reference.
We will document and be consistent! We've heard those words before from our examiners!
Thank you for all the input. I'll get with our CRA officer to see about using his Wiz.

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#423437 - 09/16/05 07:01 PM Re: HMDA ~ FFIEC vs. American Fact Finder
Anonymous
Unregistered

Forgot to address the appraisal issue. The appraiser's map shows the subject property with an arrow that's vague and then another arrow for one of the comp's which contradicts the location of the subject property.

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#423438 - 09/16/05 08:19 PM Re: HMDA ~ FFIEC vs. American Fact Finder
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
The best advice I can give you is NEVER use the geocode on an apprasial or Flood Certificate. Its been proven that over 30% of them are inacurate. Of course you may have a source that is Ok.

When using FFIEC or other geocoders, unless you can get a print out of the "Match" code, you will not know at which level of accuracy an address was geocoded.

Match Levels vary between vendors but most are set up this way

Exact Match or Street Level Match (Best Accuracy)
Zip+4
Zip+2
Zip (5 digit and generally not acceptable if there are more than 1 tract inside the zip code boundry) If there are say 3 tracts within the zip code a geocoder puts the location in the center (centroid) of the zip code, which could be in any of the 3 tract depending on their boundaries.
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