Our bank has opened two new branches this year in two different states. What do I need to do? At what point must I report CRA data for these areas. When does it become the bank's assessment area that must be included in the CRA reportable data?

Thanks for your help!!!

From page 8 of the CRA Guide:
For institutions other than those
designated as wholesale or limitedpurpose
(see the glossary),
assessment areas must consist
generally of one or more metropolitan
statistical areas (MSAs) or
one or more contiguous political
subdivisions such as counties,
cities, or towns. An institution must
include the geographies in which its
main office, branches, and deposittaking
ATMs are located as well as
the surrounding geographies in
which it has originated or purchased
a substantial portion of its loans.
Please refer to section __.41 of the
regulations and the interagency
Qs&As for further guidance,
particularly Q&A __.41(e)(4)–1,
which explains limitations on the
size of assessment areas.
Note: When you are entering
information about small-business
and small-farm loans, you need to
provide MSA, state, county, and
tract/BNA information to indicate the
location of the loan. The information
that you provide in the loan data
entry screens is not your assessment
area(s). This is simply the
loan’s location.

Glossary, Page 23:
Assessment area(s). One or more
geographic area(s) delineated by an
institution and (if delineated in
compliance with the regulation) used
by the regulatory agency in
evaluating the institution’s record of
helping to meet the credit needs of
its community. The assessment
area(s) for an institution other than a
wholesale or limited-purpose
institution must:

consist generally of one or more
MSAs (using the MSA boundaries
that were in effect as of January 1
of the calendar year in which the
delineation is made) or one or
more contiguous political
subdivisions, such as counties,
cities, or towns; and

include the geographies in which
the bank has its main office, its
branches, and its deposit-taking
ATMs, as well as the surrounding
geographies in which the bank has
originated or purchased a
substantial portion of its loans
(including home mortgage loans,
small-business and small-farm
loans, and any other loans the
bank chooses, such as those
consumer loans on which the
bank elects to have its
performance assessed).
An assessment area(s) must consist
only of whole geographies, may not
reflect illegal discrimination, may not
arbitrarily exclude low- or moderateincome
geographies, taking into
account the institution’s size and
financial condition, and may not
extend substantially beyond a CMSA
boundary or beyond a state
boundary unless the assessment
area(s) is located in a multistate
MSA. An institution may adjust the
boundaries of its assessment area(s)
to include only the portion of a
political subdivision that it
reasonably can be expected to
serve.

You have to include in your Assessment Area any tract in which you maintain a deposit-taking branch. If you are in multiple states you are supposed to have a different Assessment Area for each state unless you are in a multi-state MSA. Even then, you may want to declare separate AA's because the examiners will breakout your data that way for performance evaluation purposes and most CRA officers would like to analyze their data like an examiner would so they can anticipate exam quesstions. If you are a reporter, you will have to report all your small business and small farm loans whether they are inside your AA's or not. So your last question conveys a misunderstanding about what you must report under CRA. Are you a Large Bank or voluntary CRA reporter?

Large Bank