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#1796602 - 03/20/13 04:05 PM want to add more tracts-help
Trees Offline
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Joined: Apr 2005
Posts: 4,013
I am the CRA officer and I have been managing the CRA delineated area since I got the job. We never changed tracts....until now. Our current area is only a partial county. We want to add more tracts. I pulled the Reg. I read section 228.41. I don't see where we have to submit any kind of proposal to the regulators. I suppose we need to submit info to our board for approval, i.e. we want to add tracts 1,2,and 3. they are close to our current tracts, they are in our MSA and we commit to assisting in the development of the area (board membership, donations, etc.) We will also explore the possibility of building a branch to serve the area. Is this all we have to do? Can we then get a map showing the "revised" area with tracts, etc. Not sure what examiners will look for? HElp!

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#1796604 - 03/20/13 04:09 PM Re: want to add more tracts-help Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You can add tracts as the bank sees fit with no regulatory approval. You just need to do a proper assessment to decide what tracts make sense for your bank (where you are lending regularly, where branches are, etc.)

Once you change your AA you will need to update your maps for your public file.

Your internal approval process for assessment area changes is purely a bank decision but it makes sense to involve the areas that must deliver the loans, consider branch locations, etc.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1796647 - 03/20/13 04:56 PM Re: want to add more tracts-help Trees
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Whew. That helps. I need to win that Powerball, and soon!

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#1798155 - 03/25/13 06:52 PM Re: want to add more tracts-help Trees
B_F Offline
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B_F
Joined: Nov 2006
Posts: 7,228
Cincinnati, OH
Trees, be careful not to arbitrarily add tracts. Look for geographic boundaries if you can. Whether a river, highway, town or township, or county line, you are better off using it than just selecting census tracts. Also, if you are just chosing tracts, be careful not to end at a high minority or low income tract.

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