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#2023671 - 06/29/15 01:45 PM Assessment area and marketing products
I'm Not A Banker Offline
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I'm Not A Banker
Joined: Jan 2015
Posts: 85
Admittedly it's Monday and my mood is not tolerant of too much this early in the week. Having said that, our marketing department is pushing back on including prospects in a direct mail piece that includes people in our new assessment area. We will officially change the AA this week with the opening of a new location and the mailing will drop in the coming weeks but I'm getting resistance on including that new county in their mailing. Other than showing the definition of what an AA is, is there any other resource out there I can site that will explain why it's important to include our entire new AA? Thanks.

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CRA
#2023690 - 06/29/15 02:04 PM Re: Assessment area and marketing products I'm Not A Banker
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Why in the world would you not include this new area that is now part of how the bank's performance is measured? In your next exam, performance in that market will count.

Why should these people not be informed of the bank's products? It is to the bank's advantage.

If the direct mail mentions lending you will have to ensure that these people in the new AA receive the same advertising at some point within a reasonable time or your advertising is not being targeted fairly, so why not now?
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2023703 - 06/29/15 02:46 PM Re: Assessment area and marketing products I'm Not A Banker
I'm Not A Banker Offline
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I'm Not A Banker
Joined: Jan 2015
Posts: 85
Thank you Kathleen. I agree 100%. To answer your why questions I would have to speculate. I hope the discussion will be enough to convince. Thanks again.

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#2025228 - 07/03/15 09:18 PM Re: Assessment area and marketing products I'm Not A Banker
JC (Darth HMDA) Offline
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JC (Darth HMDA)
Joined: Dec 2013
Posts: 1,399
CA
Agree with KB (as usual) smile

Sigh... Marketing...

I would conduct research on the demographics of the new AA. If the new AA is a higher percentage LMI, or has a higher percentage of minority residents, you should definitely bring this to management's attention. We just went through an exam and the examiners thoroughly, and I mean thoroughly, reviewed our marketing plans and any direct mail campaigns. If they find out your advertising lending in one area and excluding LMI/high minority areas you could be in a world of hurt.

And like KB said, why on earth wouldn't they want to expand their presence and build brand recognition in the new AA? Seems like good old fashioned business sense to me.

Best of Luck!
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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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