HMDA Data Outreach: Review Data for Invalid Entries in the Street Address Field

Update

4/18/2023

A customer reached out to the CFPB HMDA Help and received the following reply:

Hello,

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.

Thank you,

CFPB HMDA

This definition is a short-term solution to help identify addresses that the CFPB considers invalid. Without official specifications we cannot guarantee this will identify all situations. As a last step, you will want to manually review all street addresses in a list view.

Thanks to all of you that forwarded copies of what the CFPB sent out regarding address quality. It seems that the CFPB has been sending a form letter to institutions regarding address quality issues that may exist in the submitted HMDA data over the last several years. It must be noted that there are no published specifications for edit checks in the Filing Instruction Guide (FIG), or in any supporting documentation such as the HMDA Guide to Getting It Right, regarding address quality. The letter currently being circulated is an "off-the-cuff" document that has never appeared in years past and seems to be directed at all HMDA filers in an attempt to force postal quality address structures on all addresses being submitted. While we do think it is unreasonable to just pop this out of the blue, there are a few different ways to look for the offending addresses in RATA.

Again, to be clear, there are no official edits to run that look for addresses the CFPB might deem "errors". They have listed a few scenarios but there are many more and many exceptions. To come out of the blue and make it sound like this is something institutions should have been looking for is very odd. Also, to give 30 days to review 3 years of data and possibly resubmit without warning is unreasonable at best. But the biggest problem we see with this is the fact that many US post office address standardizers, or manual geocoding processes (like RATA uses), can fix many of these issues and RATA does that regularly. Yes, some of the things they mentioned can lead to fallback geocoding, and RATA recommends that all of our clients review the Low Probability ZOOM records to see if address improvement is needed.

We are looking at methods that we might be able to incorporate into Comply in the form of RATA Quality edits to help identify some of the examples in the CFPB's document, as well as other variations that we see quite often that the CFPB did not even list. Since the CFPB knows exactly what they're looking for, it would have been more helpful to create edit checks themselves, which may appear in the future, but for now we will attempt to implement some checks for the majority of the issues outlined.

We suggest the following:

1. We have created a custom edit check definition that will identify addresses that need to be reviewed. You can run these custom edit checks, filter to the applications that failed the edits, and then work on any that can be improved.
• To load this definition into Comply from email:
• Save the definition file (.xml) out of this email
• In Comply, go to the Home ribbon
• Click the Definitions button to open the Definition Manager
• Click on the top section of the Import button (or if you click the drop-down select Import Definition File)
• Browse to the .xml file, highlight it, and click Open
• Finish the wizard
• To load this definition into Comply from the support site:
• In Comply, go to the Home ribbon
• Click the Definitions button to open the Definition Manager
• Click on the top section of the Import button (or if you click the drop-down select Import Definition File)
• Select the radio button to Import definitions from the RATA Support Site then click Next
• In the Custom Edit Check section, check the box next to Street Address Validation
• Click Next and finish the wizard
• To assign this custom edit check definition to your reporting entity:
• Right-click on your reporting entity and select Properties
• Go to the Edits tab
• Check the box in the Custom Edits section to Enable Custom Edit Checks
• Select this definition from the drop-down: Street Address Validation
• If you already have a custom edit check assigned, you can change it to this one, temporarily, then change it back to your own at a later time
• Click OK to save your changes
• Run the Partial Edits on your reporting entity
• Filter on the custom edits:
• Click the Filter button on the Applications ribbon and select Filter to open the Filter Designer
• Double-click on Edit Check Expression
• Go to the Custom tab
• Click the All >> button to add all custom edits over to the right-hand side
• Click OK
• Click OK again to run the filter
• Switch to a List View in order to quickly view the Street Address (Original) field for all applications meeting the filter criteria
• Make any necessary changes to the street address field. After making a change, click the Save button on the Applications ribbon or simply click on another record.
2. If you made any changes to your addresses or geocoding, you will need to resubmit:
• Highlight your reporting entity
• Click the Submission button on the Data Manager ribbon
• Select the option to Reset and recreate the submission
• Go through the wizard to create your new submission file
• Upload that new file to the HMDA Portal

Here are some other things you can do while waiting for the custom edit check definition (or even in addition to the above):

1. Run the Geocode Precision Report. From the Applications ribbon, click the drop-down of the Geocode button and select View Geocode Precision Report. If your overall precision is 95% or higher that is a great start. Either way, there are most likely addresses that can be improved, which in turn will allow you to obtain better geocodes.
2. Comply identifies applications where the geocode precision does not meet compliance-grade requirements. The ZOOM Low Priority group includes 5-digit ZIP centroids without a ZIP+4 assigned, which means that the address was not recognizable by the USPS. To filter to these applications: 
• Right-click on your reporting entity and select Properties
• Go to the Status tab
• Click the link for ZOOM Low Priority
• Switch to a list view and review the Street Address (Original) field. You may find addresses that can be improved; TBDs, Lot numbers, and parcels - just to name a few.
• If you change an address, the geocoding for that application will disappear. Once you're finished making all address changes, you can do a geocoding export.
• After receiving both the B and R files back, you'll want to filter to the ZOOM Low Priority applications again, and this time, ZOOM them one by one. With moderate effort using the ZOOM Geocoder, it's possible to obtain more solid geocoding results for these addresses.
3. If you didn't already review the ZOOM High Priority addresses before submission, now would be a good time to do that too. This group includes all ZIP+2 centroids and 5-digit ZIP centroids with a standardized ZIP+4 assigned. To filter to these applications:
• Right-click on your reporting entity and select Properties
• Go to the Status tab
• Click the link for ZOOM High Priority
• ZOOM these addresses one by one. With minimal effort using the ZOOM Geocoder, there is a high probability that more solid geocoding results can be obtained for these addresses.
4. If you made any changes to your addresses or geocoding, you will need to resubmit. If you are going to use our custom edits, you will want to wait to resubmit until you receive our definition and complete those steps as well.
• Highlight your reporting entity
• Click the Submission button on the Data Manager ribbon
• Select the option to Reset and recreate the submission
• Go through the wizard to create your new submission file
• Upload that new file to the HMDA Portal

For more information on how to utilize the ZOOM Geocoder, please see the Best Practices document, pages 6-12. This is located on the Start Page tab in Comply, under Resources > Geocoding. 

If you have further questions, please email them to support@rataassociates.com or call and we will be happy to discuss.