We are a large bank under FDIC, although I'm not sure that matters with my question. When your bank has changed your assessment area, who makes that decision?

Most banks would have executive management approve the recommendation by the appropriate officer responsible for CRA, Community Development and Compliance matters.

It would not require immediate board attention. Such board action could wait if it typically approves the AA annually. But that is not to say the board couldn't be made aware at a monthly meeting and accept the report.

What Pale Rider said is our process. Our Board approves our AA annually, and if we have any changes during the year, we present at the next available board meeting to let them know/why we are changing our AA.

The Regulation does not require Board approval but it is a best practice since it demonstrates the Board is exercising its oversight responsibility.

Thank you everyone. This is a pretty sticky decision for us because of the social climate our region is in. Our CRA committee made a recommendation to the board for board approval.