The 2021 FFIEC Median Family Income report came out. For CRA- do we use the 2015 number or the estimate of the 2021? Why are both numbers on the report?

The annual EMFI is used to determine the income class of mortgages processed during the year. The 2015 number is used to determine the tract income class and is adjusted every 5 years or sooner if the tract is in a MSA (or non-MSA) that has changed in its composition as determined by OMB. The FFIEC then uses this determination for the following year. During 2020 OMB did issue some minor changes in CMBA's, CSA's, and MSA's. So some tracts in the affected MSA's could have changed the "2015" number which means their income class could be changed.

I haven't reviewed in detail the 2020 changes published by OMB, but we have published a map that's available online to the public (see an earlier post a few weeks ago about MSA maps). If you are in a MSA that changed then you should watch to see if any tracts income classes changed. The FFIEC has not issued the official 2021 demographics as of today. But you can anticipate a change if you observe a change in your MSA in the map.

Between 2018 and 2019 there were some changes that affected several MSA's and MD's and therefore census tracts and some of the commercial CRA software did not capture this and reflect it in their 2019 tract demographics.

Here are the most significant changes implemented for 2019 that some software companies did not capture (I am not sure if they have corrected their files, but I know they were using the wrong data for much of 2019).

Changes for Current (2019) Census File
MSA Changes:- The following updates announced by the Office of Management and Budget (OMB) on September, 2018 will be included in the 2019 FFIEC Census File:

a. New Metropolitan Statistical Area: Poughkeepsie-Newburgh-Middletown, NY (MSA 39100, consisting of Dutchess County (027), Orange County (071)).

b. New Metropolitan Statistical Area: Yauco, PR (MSA 49500, consisting of Guánica Municipio (055), Guayanilla Municipio (059), Peñuelas Municipio (111), Yauco Municipio (153)).

MD Changes:

a. New Metropolitan Division: Frederick-Gaithersburg-Rockville, MD (MD 23224, consisting of Frederick County, Montgomery County).

b. New Metropolitan Division: New Brunswick-Lakewood, NJ (MD 35154, consisting of Middlesex County, Monmouth County, Ocean County, Somerset County).

c. Remove Metropolitan Division: Dutchess County-Putnam County, NY (MD 20524, consisting of Dutchess County, Putnam County).

d. Remove Metropolitan Division: Silver Spring-Frederick-Rockville, MD (MD 43524, consisting of Frederick County, Montgomery County).

No changes were announced for the 2020 year but during 2020 OMB did change some MSA's so you can expect that the FFIEC demographics for 2021 will reflect those changes. No 2021 Demographics have been issued yet.

So with the new Median numbers coming out this week ( https://www.ffiec.gov/Medianincome.htm ) do I use the 2015 or the 2021 estimate if the MSA has not changed. Im just confused because they are both on the spreadsheet for 2021.

Right now all they posted are the 2021 EMFI for the MSA's and the "non-Metro Portion" of each state. The 2021 numbers are to be used to compute the income class of 2021 HMDA mortgage borrowers. The 2015 data is useless unless you know how to translate it into tract income class calculations which I doubt a single banker in the entire country knows how to do.

BTW, if your MSA Median Family Income has not changed it's a good indication that the income class of tracts has not changed. I hope to get some time to review the 2020 OMB changes which will be used by the FFIEC for tract income class determination for 2021 and I will try to post something about that in the next week.

GeoDataVision has been publishing free public maps for the last month. So far we've published maps for 2021 MSA's, CSA's and MD's. In the next few weeks we plan to publish maps on majority-minority tracts and tracts by their income class.

OK I finally broke down and decided to review OMB Bulletin No. 20-01 which is the last bulletin I find that is published by OMB regarding Statistical Areas and is the source used by the FFIEC. That Bulletin states that Wells County IN was added to the "Fort Wayne-Huntington-Auburn, IN" CSA. No changes were made to the configuration of the MSA's although a few name changes in various geographic components were announced. This means there should be no changes in the tract income class of individual tracts from what they were in 2020.

Here is the relevant excerpt from the Bulletin:

0MB Bulletin No. 20-01 Attachment

UPDATES TO STATISTICAL AREAS

Application of the 2010 Standards for Delineating Metropolitan and Micropolitan Statistical Areas to Census Bureau population estimates for July 1, 2017, and July 1, 2018, results in designation of one new micropolitan statistical area and one new component of an existing combined statistical area. The complete lists of statistical areas incorporating these and other changes are provided in the appendix to this bulletin.

New Micropolitan Statistical Area with Principal City and County Component
14160 Bluffton, IN Micropolitan Statistical Area Principal City: Bluffton
Wells County

New Component of Existing Combined Statistical Area
The Bluffton, IN Micropolitan Statistical Area is added to the Fort Wayne-Huntington-Auburn, IN Combined Statistical Area (code 258).

Other Changes

Bridgewater town, MA, a component of the Boston-Cambridge-Newton, MA-NH Metropolitan New England City and Town Area (and Brockton-Bridgewater-Easton, MA New England City and Town Area Division), is now Bridgewater Town city, MA. The new title of the New England city and town area division is Brockton-Bridgewater Town-Easton, MA New England City and Town Area Division.

Framingham town, MA, a component of the Boston-Cambridge-Newton, MA-NH Metropolitan New England City and Town Area (and Framingham, MA New England City and Town Area Division), is now Framingham city, MA.

Randolph town, MA, a component of the Boston-Cambridge-Newton, MA-NH Metropolitan New England City and Town Area (and Boston-Cambridge-Newton, MA New England City and Town Area Division), is now Randolph Town city, MA.

The 2021 Demographic file was released late last week and we are reviewing it now. But as I said in the previous post, there should be no changes to the tract income classes from what they were in 2020 because OMB did not change the composition of the MSA's. It is interesting to note that the FFIEC demographic notes document states something confusing:

Geographic and other changes in the 2021 FFIEC Census File:

1. FFIEC Estimated Median Family Income Data and geographies used by HUD in the calculation of HUD MFI are described in documentation linked from this page: https://www.huduser.gov/portal/datasets/il.html. However, since the ACS estimates used by HUD do not include the revisions to the MSA/MD delineations released by OMB in September 2018, MFIs for the following geographies were calculated as they were for the previous year by the FFIEC:

As I have documented in a previous post, the delineation of MSA's, MD's, etc., are determined by OMB which issued a bulletin during 2020 regarding these geographies. The FFIEC by omitting reference to the latest OMB Bulletin about this matter creates potential confusion as to whether it has been updated for the latest OMB definitions. Although the changes were very minimal, at least one CSA was affected which is relevant to AA delineation rules in subsection .41 and therefore relevant to 2021 demographics.