Recently the FFIEC posted the latest revised list of Distressed and Underserved tracts as defined in the revised CRA. This is the third time in the last 9 months the "annual" list has been posted. The latest list shows some very dramatic changes in the qualified distressed tracts. Specifically, there were 691 distressed tracts dropped from the previous list and 164 added. The previous number of Distressed tracts was 3,079. Now the count is 2,552. Since there is a 12 month "lag period" following the termination of the tract distressed status it is important for banks to be aware of the identity of these "lame duck" tracts if they are planning any qualified community development activities in those tracts. The FFIEC listing does not highlight those terminated tracts, although it does have a field that indicates previous status which must be compared to the current classification.

I want to make sure I understand the "lag" period...We still get credit/possible credit for activities (lending, investements, services) in those designated areas for 1 yr. from the original designation?

Lyndsey, you get credit for qualified CD activity in those areas that occurs within 1 year after the tracts have been removed from the list. This is another complication from the "regulatory relief" provided by the revised CRA.

As always, thank you Len.