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#1977851 - 11/20/14 06:31 PM Self Evaluation Data Assistance
mgs41 Offline
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Joined: Jan 2007
Posts: 167
I'm in the process of completing my first self evaluation. I'd like to include (as did our last public evaluation) data by county on businesses by type of census tract. For example, x number of businesses in low income, x number in moderate income. I would have thought that I could find this via Census data, but I'm having some real difficulty:(

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CRA
#1977904 - 11/20/14 07:45 PM Re: Self Evaluation Data Assistance mgs41
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,401
CA
Pardon my asking, but I am not fully understanding the question.

Are you asking how to find data on all businesses within a county, by tract income-level? Or is is specifically regarding your loans to businesses?

Sorry to ask.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#1977912 - 11/20/14 08:11 PM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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The exam data is drawn from D&B data, which the industry keeps telling the regulators is unvalidated and flawed, as well as quite expensive. Price depends upon where you are located. You might get lucky and find exam reports that have the current data for the counties you are interested in!
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1977916 - 11/20/14 08:18 PM Re: Self Evaluation Data Assistance mgs41
mgs41 Offline
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CRA/HMDA Guy - yes - general business size data by tract - public info rather than anything related to our banks loans.

Kathleen B - when you wrote "You might get lucky and find exam reports that have the current data for the counties you are interested in!" do you mean "borrowing" data from other banks Public Evaluations?

Thank you!

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#1977924 - 11/20/14 08:22 PM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Yes! I wouldn't publish it in a report to examiners, but if I wanted a measure for myself (as a banker at a bank), it is out there in exam reports - if you find one that matches your area.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1977927 - 11/20/14 08:32 PM Re: Self Evaluation Data Assistance mgs41
CompliantOkie Offline
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OOOOOOklahoma
Other bank's PE's are wonderful resources. I frequently check PE's for our competing banks as well as similarly situated banks nationwide and across regulators.

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#1977933 - 11/20/14 08:41 PM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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It is impossible to manage CRA without reviewing other banks' PEs.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1977959 - 11/20/14 09:24 PM Re: Self Evaluation Data Assistance mgs41
CompliantOkie Offline
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CompliantOkie
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OOOOOOklahoma
^ Agree but you would be surprised how many people don't read other PE's. That was the first thing I started with after reading the Reg and Q&A's when I first started working with CRA.

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#1978026 - 11/21/14 03:42 AM Re: Self Evaluation Data Assistance mgs41
Len S Offline
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Joined: Oct 2004
Posts: 2,155
Connecticut
Examiners have told me they will supply the business demographic to bankers for their AA's if they request it. But as Kathleen said, I believe the data is unreliable. Nevertheless examiners use it. A more relevant and realistic standard is the experience lending to very small businesses by all reporting lenders in your community.
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#1978030 - 11/21/14 05:51 AM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Wouldn't that be a contract violation to share it in that manner? (And I have never seen examiners do that.) The whole thing should be dropped.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1978833 - 11/24/14 11:45 PM Re: Self Evaluation Data Assistance mgs41
Wannaknow Offline
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The Centrax CRA software we use has all of that information in it. It is spot on with the examiners.

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#1978842 - 11/25/14 02:47 AM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Yes, vendor software or direct from D&B are the sources, or exam reports that coincide..or as Len mentioned, perhaps from examiners It still is bad data with no validity, no basis in reality.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1979227 - 11/25/14 11:39 PM Re: Self Evaluation Data Assistance mgs41
JC (Darth HMDA) Offline
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Posts: 1,401
CA
I agree with wannaknow. We also use CenTrax which has a wealth of information.

And reading other Bank's PE's is extremely helpful, especially if you have similar footprints.

Good Luck!
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#1980229 - 12/02/14 03:38 PM Re: Self Evaluation Data Assistance mgs41
Len S Offline
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Joined: Oct 2004
Posts: 2,155
Connecticut
There is free data relating to reported HMDA and CRA lending on the FFIEC site. Alternatively, you could purchase it from a commercial source that compiles the data into user friendly reports. If you want to know more about the latter pm me.
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#1981466 - 12/05/14 10:45 PM Re: Self Evaluation Data Assistance mgs41
mgs41 Offline
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Joined: Jan 2007
Posts: 167
Thanks everyone. This has been very helpful.

Last question - I hope...

I've been able to find aggregate HMDA data by census tract and income level for my MSA's, but I have some non-MSA counties that I'm having no luck with - any solutions?

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#1981470 - 12/05/14 11:32 PM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You can download a little program at FFIEC site, HMDA Raw Data....the very first item on this page.

http://www.ffiec.gov/hmda/hmdaproducts.htm

It contain every HMDA LAR Iin the country.

You can access by financial institution, agency, or geographic area.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1981477 - 12/06/14 12:18 AM Re: Self Evaluation Data Assistance mgs41
mgs41 Offline
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Joined: Jan 2007
Posts: 167
Thank you so much - mystery solved:)

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#1981478 - 12/06/14 12:26 AM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Good for you for doing the analysis.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1981479 - 12/06/14 03:34 AM Re: Self Evaluation Data Assistance mgs41
mgs41 Offline
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Joined: Jan 2007
Posts: 167
It's been required of our bank by our examiners, but I've found I know much more about our assessment area now than I did before!

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#1981480 - 12/06/14 03:40 AM Re: Self Evaluation Data Assistance mgs41
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Well, that is an incentive. Looking at HMDA data can reveal that other banks are making loans in parts of your AA where you have none. Great topic for discussion....why not?
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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