The Board ultimately is responsible for your compliance with any and all regulations, including CRA. Although CRA itself does not explicitly require Board approval of changes to the Assessment Area it certainly would be a poor reflection on the compliance process if such a critical decision were made without Board approval. The decision on how to delineate your assessment area may be your most important CRA decision because it affects every other aspect of your CRA performance. Furthermore, examiners not only assess your performance under CRA, they observe the "process" itself. If the Board does not have compliance controls in place that assure it is informed about important compliance decisions, it would seem to me to be a glaring omission. Finally, why wouldn't the Board be involved in such a decision? Don't forget that the Assessment Area is supposed to define your market. Aside from its compliance implications it is a strategic market decision that should involve the highest levels of authority within the bank.
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