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#1901815 - 03/03/14 10:53 PM CSA and New Q&A
ksm Offline
Gold Star
ksm
Joined: May 2003
Posts: 302
Midwest
I am looking for information about CSAs. Please provide link(s) if possible.

I went to the FDIC Examinations site and the links for the last Q & A says 2010. Is there a link to the new Q & As or was the 2010 document just updated? Do you know when it was update?

Any other advise on changes would be greatly appreciated!!!

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CRA
#1901827 - 03/04/14 12:08 AM Re: CSA and New Q&A ksm
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
The updated Q and A is available at the FFIEC CRA site:

http://www.ffiec.gov/cra/qnadoc.htm
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1902227 - 03/04/14 10:47 PM Re: CSA and New Q&A ksm
ksm Offline
Gold Star
ksm
Joined: May 2003
Posts: 302
Midwest
Thank you for the link. We have two assessment areas one for each MSA and a couple of nearby tracts. The two MSAs are now a CSA. Does this mean we should just have one assessment area now? Can I add a few more tracts outside of the two MSAs or CSA? Should I disclose this as one assessment area? I do not see a definition of extending substantially across the boundaries. Any help would be appreciated.

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#1902255 - 03/05/14 04:49 AM Re: CSA and New Q&A ksm
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,138
Connecticut
The Regulations pertaining to Assessment Area delineation proscribe "substantial" encroachment over MSA boundaries. However, when MSA's or non-MSA geographies are within the same CSA you may cross the MSA boundaries and maintain one AA as long as the area is contiguous.

When examiners evaluate your CRA performance they will breakout AA's constructed in this way into the MSA's that constitute part of the AA as long as you have at least one deposit-taking facility in each MSA. If you simply have branches in only 1 MSA then they will evaluate the AA as the combination of AA's.

The new (2013) Q&A did not change anything with respect to this topic.
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