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#2287726 - 08/16/23 05:05 PM
OMB Bulletin 23-01
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Diamond Poster
Joined: Nov 2004
Posts: 2,310
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When the FFIEC posted about the 2023 income limits being available, they made mention of an OMB Bulletin 23-01. I found that bulletin and it mentions revisions to MSAs, etc. but doesn't detail what changed. The FFIEC said they won't incorporate the boundary changes until 2024. Has anyone found an article online that explains what MSAs might have changed? Thank you. https://www.whitehouse.gov/wp-content/uploads/2023/07/OMB-Bulletin-23-01.pdfMajor changes or additions to the FFIEC Web site for 2023: (most recent first) August 10, 2023 The FFIEC released the 2023 Census flat file and the 2023 FFIEC Median Family Income Report. A second release of the flat file later this year will include demographics for the four island areas, followed shortly thereafter by the final 2022 flat file release. This release does not include boundary changes from OMB Bulletin 23-01 (or any future bulletins for 2023); these will be included in the 2024 release next year.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#2287796 - 08/17/23 05:50 PM
Re: OMB Bulletin 23-01
Reads Regs
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Diamond Poster
Joined: Oct 2004
Posts: 2,127
Connecticut
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There will be no changes to tract income class for 2023 vs 2022. However, the EMFI will be different because it changes annually. This does not pertain to the tract income class. It pertains to the borrower income class.
Finally, it looks like the FFIEC finally has provided the breakdown of the Hispanic population by race which it had not done during 2022.
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps
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#2287807 - 08/17/23 06:57 PM
Re: OMB Bulletin 23-01
Reads Regs
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Junior Member
Joined: Nov 2001
Posts: 40
WV
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Hi - I have a follow-up question related to timing. We have several changes as noted in the OMB release. The census bureau indicates the changes in the OMB are effective July 2023. With the FFIEC indicating that the OMB MSA changes will not be included until 2024, does that mean that for CRA purposes, the OMB changes are not effective until 2024?
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Six consecutive "Outstanding" Large Bank CRA Ratings.... and counting.
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#2287919 - 08/22/23 03:46 PM
Re: OMB Bulletin 23-01
Reads Regs
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Diamond Poster
Joined: Oct 2004
Posts: 2,127
Connecticut
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The FIEC always follows the OMB in the next year. It's impractical to implement the changes mid-year. Typically, in December the FFIEC will announce the tract income class for each tract to be implemented in the succeeding year. You can use the OMB announcement as a forewarning of changes to come but it's the FFIEC timetable that counts for CRA and HMDA purposes.
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#2288062 - 08/25/23 07:15 PM
Re: OMB Bulletin 23-01
Len S
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Junior Member
Joined: Nov 2001
Posts: 40
WV
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Thank you, Len.
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Six consecutive "Outstanding" Large Bank CRA Ratings.... and counting.
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#2288155 - 08/29/23 05:59 PM
Re: OMB Bulletin 23-01
Reads Regs
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Diamond Poster
Joined: Oct 2004
Posts: 2,127
Connecticut
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BTW - I've reviewed the 2023 FFIEC demographics and there appear to be no changes except for the annual EMFI and the breakdown of the Hispanic population by race.
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#2295837 - 04/12/24 02:31 AM
Re: OMB Bulletin 23-01
Reads Regs
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Diamond Poster
Joined: Nov 2004
Posts: 2,310
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I noticed that in NJ MD 35154 within MSA 35620 is now MD 29484.
35620 New York-Newark-Jersey City, NY-NJ Metropolitan Statistical Area Principal Cities: New York, NY; Newark, NJ; Jersey City, NJ; Lakewood, NJ; White Plains, NY; New Brunswick, NJ
29484 Lakewood-New Brunswick, NJ Metropolitan Division Middlesex County, Monmouth County, Ocean County, Somerset County
35004 Nassau County-Suffolk County, NY Metropolitan Division Nassau County, Suffolk County
35084 Newark, NJ Metropolitan Division Essex County, Hunterdon County, Morris County, Sussex County, Union County
35614 New York-Jersey City-White Plains, NY-NJ Metropolitan Division Bergen County, NJ; Hudson County, NJ; Passaic County, NJ; Bronx County, NY; Kings County, NY; New York County, NY; Putnam County, NY; Queens County, NY; Richmond County, NY; Rockland County, NY; Westchester County, NY
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#2295873 - 04/12/24 06:31 PM
Re: OMB Bulletin 23-01
Reads Regs
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Diamond Poster
Joined: Oct 2004
Posts: 2,127
Connecticut
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Yes there were numerous changes to MSAs which impact tract income class (not race or population demographics or housing demographics). Everyone should check to see if they are in an area affected by the updated MSAs. You can be affected directly if you are located inside a MSA that's changed (add or drop a county). You can be affected indirectly by being in a non-MSA statewide area and 1 or more of the counties are then incorporated into a MSA. This will require the recalculation of tract income class for all tracts that stay within the statewide non-MSA area.
We processed hundreds of AA map orders during March. We've been around for 30 years and it was never busier than it was in the last 2 weeks of March!
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps
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#2296022 - 04/16/24 09:04 PM
Re: OMB Bulletin 23-01
Len S
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Diamond Poster
Joined: Nov 2004
Posts: 2,310
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Thanks, Len. I saw that the FFIEC released a document with the 2020 MSA/MD MFI in early March. https://www.ffiec.gov/pdf/msa24inc.pdf There are some MDs listed in the 7/2023 OMB bulletin https://www.whitehouse.gov/wp-content/uploads/2023/07/OMB-Bulletin-23-01.pdf that I can't find in the 3/2024 FFIEC document. I am looking for the MD MFI for MD 20700 that has Monroe County, PA and MD 25770 that has Pike County, PA. Do you think the FFIEC file has errors or was the OMB bulletin wrong?
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.
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#2296037 - 04/17/24 01:46 PM
Re: OMB Bulletin 23-01
Reads Regs
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Platinum Poster
Joined: Nov 2010
Posts: 968
USA
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Monroe County and Pike County are part of Micropolitan Statistical Areas, not a Metropolitan Division or an MSA. The FFIEC typically does not adopt the Micropolitan SA delineations.
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Opinions are strictly my own, and have nothing to do with my employer.
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