My bank is located in a rural community which isn't comprised on Census Tracts. Instead, groups of towns are identified in Block Numbering Areas. We use 3 in our AA. One runs from the border of the town our Main Office is located in to 40 miles south. We don't lend much from midpoint in that BNA because it makes no sense for the folks that live 30-40 miles south of us to travel to our town to do their banking. Examiners accept that. Our other BNA runs from that the border of the town our Main Office is in, to 30 miles west. We don't lend much there because there is again no reason for the folks 30 miles west of us to come to our town to do their banking. They have 4 times as many banking opportunities right in their onw communities. The problem is that this BNA is MODERATE. I know we can' arbitrarily exclude low-moderate income tracts (or in this case,BNA's). But it makes no sense to have it in our AA. Can I remove it? I'm afraid to because it is MODERATE.

You shouldn't be criticized for having an AA that is to big, especially based on your description here. You are getting some business from that part of these large BNAs close to you, correct? I'd keep them in and continue to document that you include the whole geography as required, and do not want to omit it because there is valuable business coming from a part of it/them.

You might want to check your geographies again. The implementation of the new Census 2000 boundaries eliminated BNA's and replaced them with census tracts. In many cases the boundaries were changed. Check the census tract look up tables in the Tools section of BOL or pm me for specific info

Len, I always worked with CTs and from the outside looking in, BNA just seemed like another word for CT. I'm sure there are finite differences perhaps denoting rural areas or something. From a CRA user's perspective I don't know that it made a lot of difference, but what was the difference?

And thanks for pointing out that BNAs are technically extinct now. I skipped that but do recall a change.

"I'm sure there are finite differences perhaps denoting rural areas or something. "

Yes they usually had a 99XX tract number. In the larger metropolitian areas there are still BNA's

Actually, the boundaries of many census tracts and former BNA's were affected. We have a special conversion file that correlates the old tracts with the new tracts. We can tell what tracts were broken up into subgroups denoted by the tract suffix ".XX", which were assimilated into other tracts, etc. There 3 types of changes that tracts may have undergone. First, there tracts that were merged into other tracts. Second, there were tracts that were split. Third there were tracts that were "revised", meaning that a small portion of the tract area was incorporated into another tract or the tract assimilated a portion of another tract. Block numbering areas have been discontinued beginning with the 2000 Census (See Census Glossary: "Block numbering area (BNA): Prior to Census 2000, a statistical subdivision created for grouping and numbering blocks within a county for which census tracts had not been established. Beginning with Census 2000, all counties have census tracts, making block numbering areas unnecessary.") There are actually files available to identify "significantly changed" tracts. We did an analysis in the Los Angeles area and observed that more than 30% of the tracts had a significant change. So I wouldn't assume that there wasn't a significant change in tract boundaries. We have the entire US file, but I haven't studied it so I can't comment on the entire country, just the areas I have studied.

The foregoing reply was from me. I forgot to sign in. I didn't mean to respond as anonymous. LenS

Wow, now I'm really confused - original poster here. I'll go to the tools and check to see if I can figure this out. According to what I can determine, my BNA numbers are still in force and they are unchanged. I like what Andy said about keeping it in for the bit of business that we do there. Thank you all for your help.

Just change the term from BNA to census tract. In rural areas the`odds are your tract boundaries did not change unless you had a significant population growth. It is possible that you had`an MSA change. So check to see if it did.

or send me a PM and I'll look it up for you

Your tract boundaries may or may not have changed with the Census 2000 tract implementation. I am suggesting that, if you haven't done so, it would be wise to check. Maybe the boundaries have been redrawn in a way that removes your dilemna. The Census web site has on-line maps that will help you make this determination. Also, you've stated the tract is "moderate". When was the last time you confirmed that? Tract income classes were revised twice in the last two years. First in 2003 with the implementation of the Census 2000 boundaries. Second, in 2004 with the implementation of the new MSA's. Back here in Connecticut, 1 of every 8 census tract's income class changed in 2004 from 2003. If you've confirmed the boundaries and the tract is a moderate income tract it would be a sensitive issue to take it out of the Assessment Area. Don, Andy and many of us know that maps can help banks in many ways. It sounds like a map would help you explain this "performance context factor" to regulators. Probably the prudent thing to do would be to create a map that shows your dilemna. Why not do this and then approach the field office of your regulator and explain your situation with the map and use them as a sounding board? You've got nothing to lose by asking.

Thank you all - original poster here. I have confirmed that the BNA numbers haven't changed and the tract is still moderate. I am in the process of explaining the community in my analysis, and the logic behind that communities shopping and banking need. Thank you all.

I did want to clarify my previous remark about Block Groups in the 2000 census. Yes there are Block Groups in the 2000 census. They were not done away with as LenS stated. Here is the 2000 defination of a Block Group as provided by the census bureau:

"A block is the smallest geographic unit for which the Census Bureau tabulates 100-percent data. It is a subdivision of a census tract. Many blocks correspond to individual city blocks bounded by streets, but blocks -- especially in rural areas -- may include many square miles and may have some boundaries that are not streets. The Census Bureau established blocks covering the entire nation for the first time in 1990. Previous censuses back to 1940 had blocks established only for part of the nation. Over 8 million blocks are identified for Census 2000."

In your area what was previously called a BNA is now the census tract. BUT as you see from the above statement there are still Block Groups for which census data can be obtained in many parts of the country.

I thought the confusion centered around block numbering areas (BNA's) not block groups. I was stating that BNA's had been discontinued. The original question referred to a block numbering area that had been classified as moderate income. As I stated originally, many census tract boundaries changed with Census 2000. Perhaps the rural areas had less change than the urban areas, but no one should assume the tract boundaries didn't change with the new Census 2000 tracts, nor should anyone assume that a tract income class didn't change from 2003 to 2004 with the implementation of the new MSA's. "An ounce of caution is worth a pound of cure". If you pm me, I can check the conversion tables to see if your tracts were affected.