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#1807353 - 04/23/13 06:42 PM LPO and redefining AA
bmw Offline
Junior Member
Joined: Jul 2012
Posts: 44
we are looking to open an LPO office that would be across state lines from our AA. i am told that the LPO will produce more loan volume than our offices in our existing AA. so that would mean that i have to extend my existing AA to include the LPO? is there an issue extending an AA across state lines?

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CRA
#1807357 - 04/23/13 06:44 PM Re: LPO and redefining AA bmw
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Is this in a different MSA?

From the AA requirements (using Reg BB, FRB version for ease):

(e) Limitations on the delineation of an assessment area. Each bank's assessment area(s):
(1) Must consist only of whole geographies;
(2) May not reflect illegal discrimination;
(3) May not arbitrarily exclude low- or moderate-income geographies, taking into account the bank's size and financial condition; and
(4) May not extend substantially beyond an MSA boundary or beyond a state boundary unless the assessment area is located in a multistate MSA. If a bank serves a geographic area that extends substantially beyond a state boundary, the bank shall delineate separate assessment areas for the areas in each state. 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.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1807446 - 04/23/13 08:53 PM Re: LPO and redefining AA Kathleen O. Blanchard
bmw Offline
Junior Member
Joined: Jul 2012
Posts: 44
yes this would be in a different msa.

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#1812352 - 05/08/13 06:47 PM Re: LPO and redefining AA bmw
B_F Offline
Power Poster
B_F
Joined: Nov 2006
Posts: 7,228
Cincinnati, OH
Is it in a multi-state CSA?

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#1812355 - 05/08/13 06:50 PM Re: LPO and redefining AA bmw
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It will have to be an "additional AA" if it extends "substantially" beyond the boundaries (more than a few incidental tracts).
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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