The Truth About Geocoding Geocode: The Inconvenient Truth 1 CenTrax Support 800-627-5388/csupport@gomarquis.com GPS - General Positioning System? Have you ever used a GPS to help you find an address you were unfamiliar with? I do this frequently when I travel and most of the time I end up right where I should be. Other times though the GPS isn’t accurate, it is close enough for me to find my ultimate destination. Every once in a while, the GPS takes me somewhere else completely. Once while visiting San Antonio, I set my destination to a restaurant only to end up at an abandoned building in an alley. It is the same with geocode. Most of the time, geocode providers get it right. Sometimes, like GPS, they are close and other times they are way off. As of December 2012 our address database contains 10,528,213 ranges (a range contains more than one address, the first one in the database is 2000-2078 Cherokee). These address ranges must be placed in the 73,918 tracts as of the 2010 census. No one is going to do that right 100% of the time. Can You Geocode Me Now? I don’t want to scare you into thinking that your geocode - regardless of where it came from - is wildly wrong. It isn’t. Whether you use us, data provided by another vendor (such as the one that provides your Flood Certifications), or the FFIEC - without looking at it I would be confident in saying that most of your geocode is accurate. But just like with GPS, some of them won’t be. This is why the CenTrax software provides the Validate options in Browse and Manual Geocode. It is also why we offer the free geocode audit service before you complete your submission or before you provide current year data for an exam. We want you to be aware of the records where providers differ so that you can decide what you want to report. Ultimately, you may be required to defend your final answer during the exam. The regulation does not require that you use a particular vendor for the geocode and submission of your reportable HMDA & CRA data. Beginning on page 18 of A Guide to HMDA Reporting: Getting it Right there is a short (and incomplete) list of resources but no specific requirement that you use any of these and pages A-4 & A-5 only refer to the requirement to provide geocode. The same general information appears on page 16 of A Guide to CRA Data Collection & Reporting. You are required to report geocode. For most of you, that requirement extends to every record, even those that, despite your best efforts, cannot be located on any geocoding system or map. You must make every effort to report accurate geocode. You should include geocode in your audits of the CRA & HMDA data. FFIEC’s Geocode is Always Correct - That’s What I Was Told This statement always makes me think of the commercial where the woman believes that everything on the Internet is true so she goes on a date with a “French model” who is neither French nor a model. 2 Copyright Marquis Software Solutions 2012 The Truth About Geocoding First, I want to point out that regardless of what anyone believes, this is not true. It is also not true that the FFIEC is the actual provider of their data. The FFIEC purchases their database from Tele Atlas. Tele Atlas is a company that provides a variety of services from geocode data to TomTom GPS devices. They are not a government agency as some would believe. CenTrax purchases data from multiple providers and creates a blended file. We are frequently asked why we don’t just buy the same data as the FFIEC and there are two primary reasons for this. Tele Atlas provides multiple options for geocode data and there is no guarantee we will buy the exact one provided to the FFIEC. But the primary reason goes back to the fact that you must geocode everything. If we purchased the same database and we were unable to geocode the record you would have few options other than manually working with mapping sites such as Google or Mapquest to determine geocode. Those of you who have used this method (all of you at some point) know this is time consuming and tedious and not very realistic for a large number of records. Having a different database allows us to geocode records the FFIEC cannot and vice versa. The FFIEC screen shows the date of their last update here. Let’s look at four geocode examples from the FFIEC database. These represent the common issues I see with geocode, regardless of who the provider is. 3 CenTrax Support 800-627-5388/csupport@gomarquis.com Example 1: 95 E Center St, Lee, MA 01238 The FFIEC returned an automatic geocode and I clicked through to see the map. Referring to Google Maps, I obtained a map for the same address. Using Columbia as a reference point, though the geocode provided was correct, the actual placement of the address isn’t the same with the FFIEC clearly east of Columbia and Google west of the same street. 4 Copyright Marquis Software Solutions 2012 The Truth About Geocoding Example 2: 1801 Hale Ave, Corcoran, CA 93212 When you enter an address, you need to watch the return information. Note the lack of a street number here on the return screen. I entered the full address as 1801 Hale Ave. This return makes it appear that any address on Hale Avenue would be in tract 0014.02. I clicked Get Street Map. I can’t tell if that street south of the triangle is a different street so let’s zoom in. 5 CenTrax Support 800-627-5388/csupport@gomarquis.com Here you can see that Hale goes both north and south of the blue line which is a tract boundary line. Hale is also the boundary on the north side of the line for two other tracts. This means that addresses on Hale could have any one of three different geocode answers. Let’s consult Google Maps. Google Maps indicates that the property is south of the boundary. If you look at the FFIEC map at the top of this page, that would place this address in tract 0014.01, not 0014.02 as the automatic return originally indicated. Note: Both of these tracts are Moderate income in the 2010 census. When a return drops the street number or modifies the address (or city/state/ZIP), we recommend you do further research before accepting the answer. 6 Copyright Marquis Software Solutions 2012 The Truth About Geocoding Example 3: 1312 Cecilia St, Taylor, TX 76574 Automatic return of tract 0212.01, no changes to the information entered. Once again, the map shows the address (the triangle) on the intersection where 3 tracts come together. 7 CenTrax Support 800-627-5388/csupport@gomarquis.com I zoomed in for a closer look. Cecilia Street would have three possible tracts, depending on the exact address and the odd/even status of that address. With the property on the south side of Cecilia the tract based on the FFIEC map above should be 0211.00 rather than 0212.01. Note: Tract 0211.00 is Moderate income, tract 0212.01 is Middle. 8 Copyright Marquis Software Solutions 2012 The Truth About Geocoding Example 4: 91 Pine, Santa Fe, NM 87508 FFIEC automatically geocodes this address, with no changes, to tract 0106.03. This map shows Pine W, Pine E and E Pine Ext all in tract 0106.03. 9 CenTrax Support 800-627-5388/csupport@gomarquis.com The features on this Google map don’t look remotely similar to the FFIEC map. Note that Google changed the ZIP to 87507 from 87508. I verified this information on the US Postal Service website. So I adjusted the map on FFIEC to match Google using the two highways (in yellow) as my point of reference. 10 Copyright Marquis Software Solutions 2012 The Truth About Geocoding If the Google map is accurate the tract should be 0013.02. Note: Tract 0106.03 is Upper income, tract 0013.02 is Moderate. What Does All of This Mean? It means that no source is 100% accurate, not even the FFIEC. This document is not intended to degrade your confidence in your geocode - no matter where it comes from. It is meant to inform you on the reality of this complicated requirement. Your examiner will use the FFIEC as their source during the exam so you should use them as your source for auditing. You should utilize the Validate tools in CenTrax. You should use the free geocode audit services we offer. We can show you the addresses that will potentially be questioned so that you can make an informed decision about what to report. How Will CenTrax Help? We will make every effort to provide the most accurate information possible in the first place. We audit our own data (using FFIEC as the source) and make adjustments as needed. We provide the Validate features in the software. We offer free yearly audits. What we cannot do is provide an automated link to the FFIEC database. We can only allow the one-by-one functionality you have today in the Validate features. If you have questions or concerns about the accuracy of your geocode contact your account representative (Noelle Smith). We will help however we can. 11