Recently a small bank client of ours underwent a CRA performance evaluation. As part of the exam, the examiners conducted a random sampling of the loan portfolio that appeared to indicate a very poor performance record with respect to Lending Test 1. The bank strongly objected and retained our firm to geo-code and map all of their loans to prove to the examiners the sample was grossly misleading (the officers knew from experience that most of their lending occured in their market). The study of all the bank's loans showed nearly 65% of them were inside the community - 25% more than the sample indicated!!
This demonstrates the risk taken by community banks that are passive about managing their CRA performance and trust their fate to a sampling. Even non-reporting banks should continue to collect and monitor their loan performance data. There are very good and very inexpensive software packages available from several vendors (we don't sell loan software incidentally) that will allow you to manage your performance and not trust your fate to a random sampling.