Hi,
We are considering offering new accounts online to areas outside of our current assessment area. Would our assessment area need to be updated and what would be the other impacts this change would potentially have on how we our evaluated for our CRA performance?
I did find this verbiage in the regulation that suggests to me that we would have to update our assessment area.
"If a bank serves a geographic area that extends substantially beyond an MSA boundary, the bank shall delineate separate assessment areas for the areas inside and outside the MSA."