Strange exam question. fair Lending hat. Examiner is pointing our the existance of minority-majority tracts, whic have been assigned a percentage. We know our tracts and, based on CRA geocoding, etc. we know that tract 123 is coded moderate. Or, xyz is coded low. Where are they getting this additional data the perentages) Anyone been asked this of examiners recently?

You can obtain your minority populations yourself at the FFIEC site.

I pulled a random NY state county here:

http://www.ffiec.gov/census/report.aspx?year=2012&county=013&state=36&report=demographic

You can map by tract minority population as well as income class.

If you review discussions here at BOL on fair lending and recently on assessment areas, you will find references to the importance of knowing the minority population as well as the tract income classes.

You should also be reviewing the fair lending exam manual and at some level beginning to assess your bank's risk.

Intersting trend. We had examiners suggest, albeit softly this time, to add tracts in another area solely for the pyurpose of adding LMI tracts to our AA. We never thought about going in this area as it has been served for years by other banks. Not sure how that would benefit LMIs - maybe to give them another choice?

I don't recall if your bank uses full or partial counties. What examiners are doing is looking at LMI and high minority population areas in your general area that you say you don't serve and saying "why not"?

Banks need to be prepared for these conversations, especially if the bank takes mail and/or internet mortgage applications, or uses RDC for business customers to make deposits.

It is important to give thought to who you do not serve.

I can tell you redlining definitely seems to be the hot topic. In the last 6 months I have seen 3 situations in which the issue has been raised and one situation which looks like it will be referred to the DOJ. In my opinion, the situations are all a stretch to accuse a bank of redlining, but there appears to be a new aggressive interpretation of the regulations regarding this issue.

Very aggressive.