Although every CRA officer is relieved by the postponement of the April 1, "applicable" date for the new FBAAs, the new Public File and the new Public Notice provisions, don't fall asleep at the wheel because the implementation of the new MSAs and MDs for 2024 has an effect on tract income classifications. If you are in a county that was affected directly or indirectly by the new MSAs and MDs you should update your public file maps.

Thank you.

The court injunction regarding the new CRA still doesn't relieve banks of the obligation to update their AA maps in light of the new MSA's and their impact on tract income classifications.