The additional underwater tracts all appear to be numbered 9901.00 or 990100 depending on your naming convention. The problem is that banks are including these tracts within their Assessment Areas because they are included on the FFIEC site. Unless you are financing a shrimp boat with a permanent mooring in the middle of a bay or body of water you will never have loans in those tracts. Consequently they will appear as lending gaps when you do lending gap analysis. This is downright silly of course.
To make matters worse, the FFIEC just e-mailed me and told me they will add back all the underwater tracts that were omitted in last year's file. This will exacerbate the problem of course. I cannot explain why the Agencies are adopting this approach. I believe there was a misunderstanding between the Census Bureau and the FFIEC regarding the identities of underwater tracts and this was the genesis of the problem. But now with the original tracts that were omitted in the 2012 files being added back in the 2013 files there is sure to be more confusion.
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