Our specific assessment is three counties, however our CRA statement states that we will also service the surrounding counties. I know I would put the surrounding counties in the total of outside our assessment area (I think). What about if we did a loan that was in another state would I even have to include it in any figures because does anyone really care about that loan when it comes to CRA?

I would not think you could exclude the out of state loan from any necessary calculations.

Given this statement, you should make sure you are analyzing your AA plus the surrounding counties for fair lending purposes.

I'd make sure you aren't muddying the waters between your CRA assessment area and your market/trade area. My CRA assessment area is essentially only the counties where I have deposit taking facilities (with one ridiculous exception based upon the strong recommendation from the FRB). Our loan policy states that we may make loans outside of that area when the lender has particular expertise. I do not want to be expected to serve all the surrounding counties from a community development donation, investment, and volunteer perspective.

Since we are doing a great job serving the defined assessment area, I am able to claim donation/investment/service credit outside the AA in some of those surrounding counties but not expected to do so. It's more icing on the cake.

I know that there is mention about using whole geographies and state boundaries.....but I have one lone adjacent county over the state line (maybe 6 miles) and I have make it a lone assessment area...Surely I'm missing something. The branch there makes as many loans in the other state as it does it's own state. Somebody please come up with an exception!