If a CRA activity benefits multiple assessment areas (i.e., counties) delineated by the bank, should we report all the affected areas or should we designate one (1) primary area for exam purposes.

If CRA best practices suggest that Bank's should report all the affected areas, how do the examiners view the activity's impact?

Please note that I'm "not" referring to activities that the bank has identified as benefitting benefitting a broader statewide or regional area.

Thanks in advance for your pearls of wisdom!!

You should describe all areas benefiting by the activity, listing them and allocating time, dollars, etc. to individual areas.

You want to show that your activities (whether they be lending, investing, or services) overall support all parts of the bank's assessment area. It would be inaccurate to say it benefited one area only, over counting for that area.

Just for clarity, are all the counties in the same MSA?

Let me pose the following.

The bank contributed $50,000 to a University for eight scholarships ($6,250 each) for LMI students living in one of the bank's 10 Assessment Areas. Not knowing who will be awarded the scholarships - (from which Assessment Area) can I spread/allocate the contribution over all 10 of the bank's Assessment Areas or $5,000 each?

Thanks in advance.