Bear with me, I have limited training in this area. I am trying to measure where we are at mid-year for geographic distribution of loans in our AA. If I take the recently released aggregate table and total the number of loans originated in our one low income census tract & divide it by the total loans originated in our MSA, will I get the number they will compare our bank to in the exam? Also, do they look at only originated loans or do withdrawns and approved, not accepted loans figure in as well? Any help that you can provide me in getting these figures right would be greatly appreciated.

I would pull the loans originated for all tracts dividing each total for the tract by the total loans originated (SB and SF totaled seperately) and do a percentage that way.
Our examiners look to see that we are adequately servicing each tract category and where the most loans are being done. Are they all in upper income areas? do you have any in a low or moderate income area? why not? That type of stuff...

Thanks for replying Rizzo. I am able to calculate my percentage of loans in each census tract. What I am having trouble with is coming up with the aggregate number that the examiners compare us to. For example "ABC Bank made .25% of loans in census tract 100, whereas the aggregate for that census tract was 2%". I cannot come up with how they are getting the 2%. Does anyone know?

Would that be the aggregate for the loans originated in your peer group?

You are talking about your bank's "penetration rate" lending in the LMI geographies. That is compared by examiners to a number of variables, one of which is the market-driven penetration rate of all lenders in your uniquely defined Assessment Area. So if 10% of your HMDA-reportable mortgages are in your AA LMI tracts one comparison would be to the compiled experience of all other lenders. Let's say you have 100 AA mortgage loans of which 10 are in your LMI tracts. That would be a 10% penetration rate. If there are 10,000 mortgages reported by all lenders in your AA and 1500 are in the AA LMI tracts, then the market penetration would be 15%. That is one number to which you will be compared. The calculation is done both for units and dollars originated. Obviously, if you are 10% and the market is 15% then the question is why are you only 2/3 the market experience. That is when you need to know the story behind the numbers. It also is good market analysis to understand your markets and the competition.
You can get the market data from the FFIEC database which is free or you can order from a commercial source such as GeoDataVision which is inexpensive (but not free) and has all the market data calculated and organized to show not only penetration rates but market rank and market share too.

Thank you Len. That is exactly what I was trying to do - keep track of my numbers in comparison to the market pentetration. The problem I was having is trying to come up with the numbers the examiners used in our previous exam. I am using the numbers in the FFIEC database and from what you've stated it sounds like I should be doing it correctly.

I appreciate all of the responses.