My predessor was able to drill down tracts and find blocks within them that are, say, moderate within the larger tract of middle. The tract number obtained was xxxx.xxx rather than xxxx.xx. Do you know where we can obtain this refinement?

You can geocode to that level, but not in the one by one FFIEC site. You would need to use a vendor that can geocode to that level or go directly to a geocoding site like TeleAtlas (that provides the geocoding at FFIEC)...TeleAtlas is now TomTom but FFIEC references TeleAtlas still.

Those blocks are not used for CRA any more - it stops at the tract level. If you wanted to use it for other purposes, such as marketing, it could make sense.

O.K. Thanks. How does that apply, then, if we know that within a tract there are both middle and moderates, for example? Should a bank list the tract number even though middles are there? Should we even use tose numbers if we are working on 2011 and 2012 loans/investments?

You should only be working with tract income and with individual income levels.

Do you mean middle and moderate income individuals in a low income tract, as an example? The tract income is still low and wherever tract penetration is addressed (how many loans are in low income tracts for example) that is all that matters. It does not matter that some people in that tract might be of a higher income level for penetration issues.

If you are assessing loans to individuals with low or moderate income you do not pay attention to the tract income level but purely to the individuals income level.

Our problem is that in one tract we actually found a street with moderate versus middle income. Overall it is middle, however. We want to include it but, as a tract rating goes, it is overallmiddle.

Trees, the regs don't call for what you're trying to do. Sounds like you're going above and beyond. My recommendation would be to collect individual income. If you do that, you'll get credit for loans made not only to low/moderate income people on that street, but in every middle and even upper income tract!

These are mostly commercial loans that we want to submit for CD consideration. Customer refurbishes 5 appt building in a middle tract. Puts 2 appartments at lower rate for affordable housing. For the CD loan section, we are forced to put middle tract number. Will the explanation of the usage be enough so the loan isn't rejected?

You are making things more complicated than they need to be. Tract income is tract income.

If your customer is offering documented affordable housing then write that up for consideration for the exam. Do NOT get into who lives on what street.

You need to fully document that the apartments are for affordable housing and are actually rented to individuals who qualify and not to someone with a higher income.

Given the correct documentation, you will obtain credit for the apartments set aside for lower income.