In an ongoing examination, an examiner has preliminarily cited a loan for being geocoded, when it was not necessary (not a HMDA loan). He states that we are prohibited from geocoding unless we're required to do it. Any thoughts on this before we ask for a specific cite? I haven't heard of this being prohibited by any regulation. We've of course already got the address (it's a RE loan). What's the big deal that someone geocoded it when they didn't need to?

Never heard of it. Maybe they meant you collected monitoring information when you weren't supposed to...

The first thought that comes to mind if you are geocoding loans when not required to do so, or you are not using it for a defined self analysis or for CRA purposes (if applicable), are you redlining?

Off the top of my head I know of no regulatory prohibition from doing geocoding, but I've been geocoding since 1991 because of HMDA, so, I've never had any reason to look for such a regulatory cite.

The GMI and the geocode issues were written up as separate issues. This was not a HMDA loan, but the officer apparently thought it was. He collected GMI and geocoded it. Our HMDA clerk knew that it was not a HMDA loan and excluded it from the LAR. I agree with the examiner that this was not a HMDA loan, and we should not have collected GMI for Reg B or C. However, I don't see the big deal on the geocoding; yes we did it when we didn't need to...but so what? It obviously wasn't for the purpose of redlining; it was because of a confused loan officer.

I would like to see the cite on that. We geocode ALL our loans, even those that don't have to be reported for CRA or HMDA.

I'm with KC, we geocode ALL of our loans.

I have never read anything that said we couldn't, shouldn't geocode or that if we did geocode that we had to use it for self analysis like some of the other data.

jap - I've never heard of such a thing! Make the examiner provide you with their cite and get that finding removed before you have your final exit meeting.

Perhaps he is confusing collection of GMI with geocoding. Geocoding can be used for things besides banking!

I geocode thousands of loan and deposit customer records, that have nothing to do with CRA or HMDA, for marketing analysis purposes for banks all over the US. I'm with the other posters, please ask for a cite that prohibits this. It would be of great interest to me.