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#1806309 - 04/19/13 04:09 AM Assessment Area delineation and red lining
Len S Offline
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Joined: Oct 2004
Posts: 2,153
Connecticut
In the last few months I have seen particularly "robust" enforcement of anti red-lining by several regulators. There seems to be a new enthusiasm for aggressively pursuing this issue even against community banks. I know of at least 3 situations where this has become an issue. Is anyone else out there seeing a trend?
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#1806310 - 04/19/13 04:19 AM Re: Assessment Area delineation and red lining Len S
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes. Regulators are pouring over assessment areas (and what is outside of AAs or between non-contiguous AAs) with fine tooth combs. Some community banks have had AAs criticized that were developed in the past few years with regulator assistance, to the point of lowering ratings but in some cases going no further.

However, I am seeing inconsistency (even in the same region, same regulator) with urban areas - some small banks being told take in the whole county (or okay to keep the whole county) while others are told cut it back this is too large for the bank.

There is a great deal of focus on minority population analysis and we are consistently working with population maps in addition to income maps to help with analysis.

Whatever the AA is, the bank has to be able to demonstrate that it understands why it is set the way it is, what it encompasses both by income class and minority population, why the bank feels it cannot serve certain areas especially if a bank takes phone and internet loan applications (!); in short, make sure there is a basis for decisions and be able to explain and justify them.
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