If in researching our 2003 CRA data we determine that we really should change our assessment area, can we do that now in 2004 before the data is submitted ... or should board approval have been obtained in 2003? Thanks.

I'm not aware that board approval is required. In fact, examiners can even change your assessment area.

One year our examiners allowed us to change the AA before the end of the exam so they wouldn't have to criticize us. Go for it !

Changing your AA as a result of self analysis is a proactive approach, one that I could not see examiners criticizing (ooh, there's a bold statement). If you are told to change your AA, that is reactive, and not generally looked upon favorably (another risky statement).

Basically, your Assessment Area is whatever you say it is when you submit your loan data and that Assessment Area should be reflected in your Public File.

The CRA statute and regulation are both silent on this, so you may change your AA at any time. I don't think it is a good idea to do that on your own though. I'd get at least your supervisor's ok, if not the board's, but that isn't required either.

BTW, want to see your examiner become short of breath and clutch his/her chest? Just wait for them to get near the end of a CRA exam, particularly a large bank CRA exam, and just mention that, oh, by the way, did we tell you we changed our AA? AR.