Collateral address - no #

Posted By: Melissa S

Collateral address - no # - 10/02/20 08:22 PM

I have a borrower who purchased a parcel of land to develop for placement of 3 mobile homes. The land in the appraisal and the mortgage was identified only as - for example - "Help Road Map 3 Lot 4"

I have been able to identify the tract code based on knowing the town and road name.

Even though I have the name of the road, do I still put NA in the street address because I don't have a number, or do I enter only the street name?
Posted By: complyorelse

Re: Collateral address - no # - 04/29/21 12:45 PM

Bump
Posted By: Adam Witmer

Re: Collateral address - no # - 04/29/21 01:12 PM

I would put NA for the address but complete the other known information. From comment #3 to 1003.4(a)(9)(i):

3. Property address—not applicable. A financial institution complies with § 1003.4(a)(9)(i) by reporting that the requirement is not applicable if the property address of the property securing the covered loan is not known. For example, if the property did not have a property address at closing or if the applicant did not provide the property address of the property to the financial institution before the application was denied, withdrawn, or closed for incompleteness, the financial institution complies with § 1003.4(a)(9)(i) by reporting that the requirement is not applicable.
Posted By: complyorelse

Re: Collateral address - no # - 05/03/21 11:32 AM

Could it be reasonably argued that consistently using "0" for the house number along with the street name in these scenarios is acceptable and more helpful to an outside party looking at the data? I have read the commentary and would prefer following the commentary and am concerned that wrong to use "0". However, we can use our system for geocoding if we use "0" and provide the majority of the address.
Posted By: Adam Witmer

Re: Collateral address - no # - 05/03/21 12:52 PM

While I agree with your logic, an auditor or examiner is going to look at the commentary I quoted so logic can't be used over the reg or commentary (or other guidance like FAQs). The only way I would consider using "0" instead of NA is if I contacted the CFPB and they said that this was an acceptable practice - and then I documented their answer for when this was brought up by an auditor/examiner. My bet is that the CFPB won't agree to this based on the commentary, but it might be worth checking with them if you are getting push back and would like to consider that option.
Posted By: rlcarey

Re: Collateral address - no # - 05/03/21 12:55 PM

And while your geocoding system may work with a "0" I doubt that means you are always getting a correct result. Many streets fall into multiple census tracts.
Posted By: Melissa S

Re: Collateral address - no # - 05/03/21 01:15 PM

Complyorelse, there are times, when I will look at the appraisal on a property, to see what the building looks like. Then I will utilize google maps satellite imaging to pinpoint the property, then switch the image to maps. At that point i can bring up the FFIEC geocoding website and pinpoint the property location there using the Google Map as a comparison. That gives me an accurate census tract.
Posted By: complyorelse

Re: Collateral address - no # - 05/03/21 02:32 PM

Thank you to all who responded; it is always most appreciated. Agreed that the commentary should be complied with, that the geocoding may not be accurate by using "0", and that we could go through several maneuvers to get a better than "0" address (although it still may not be 100% accurate address but the geocoding would be more accurate). We just need to stick to the reg and the commentary!