§__.41(c)(1) Other Units of Local Governments as Political Subdivisions
§__.41(c)(1) – 1 Q: Besides cities, towns, and counties, what other units of local government are political subdivisions for CRA purposes? A1. Townships and Indian reservations are political subdivisions for CRA purposes. Institutions should be aware that the boundaries of townships and Indian reservations may not be consistent with the boundaries of the census tracts (i.e., geographies)…
§__.41(c)(1) Wards and Districts as Political Subdivisions
§__.41(c)(1) – 2 Q: Are wards, school districts, voting districts, and water districts political subdivisions for CRA purposes? A2. No. However, an institution that determines that it predominantly serves an area that is smaller than a city, town, or other political subdivision may delineate as its assessment area the larger political subdivision and then, in accordance with…
§__.41(d) Adjustment to the Boundaries of an Assessment Area
§__.41(d) – 1 Q: When may an institution adjust the boundaries of an assessment area to include only a portion of a political subdivision? A1. Institutions must include whole geographies (i.e., census tracts) in their assessment areas and generally should include entire political subdivisions. Because census tracts are the common geographic areas used consistently nationwide for data collection,…
§__.41(e)(3) Arbitrary Exclusion of LMI Geographies in an Assessment Area
§__.41(e)(3) – 1 Q: How will examiners determine whether an institution has arbitrarily excluded low- or moderate-income geographies? A1. Examiners will make this determination on a case-by-case basis after considering the facts relevant to the institution’s assessment area delineation. Information that examiners will consider may include income levels in the institution’s assessment area(s) and surrounding geographies; locations of…
§__.41(e)(4) Maximum Size Limits on an Assessment Area
§__.41(e)(4) – 1 Q: What are the maximum limits on the size of an assessment area? A1. An institution may not delineate an assessment area extending substantially across the boundaries of an MSA unless the MSA is in a combined statistical area (CSA)). Although more than one MSA in a CSA may be delineated as a single…
§__.41(3) & (4) Inclusion of an MSA and Adjacent Counties in a Single Assessment Area
§__.41(e)(4) – 2 Q: May an institution delineate one assessment area that consists of an MSA and two large counties that abut the MSA but are not adjacent to each other? A2. As a general rule, an institution’s assessment area should not extend substantially beyond the boundary of an MSA. Therefore, the MSA would be a separate…
§__.42 Required CRA Data Collection and Reporting
§__.42 – 1 Q: When must an institution collect and report data under the CRA regulations? A1. All institutions except small institutions are subject to data collection and reporting requirements. (“Small institution” is defined in the Agencies’ CRA regulations at 12 CFR .12(u).) Examples describing the data collection requirements of institutions, in particular those that have just…
§__.42 Required CRA Data Collection Format
§__.42 – 2 Q: Should an institution develop its own program for data collection, or will the regulators require a certain format? A2. An institution may use the free software that is provided by the FFIEC to reporting institutions for data collection and reporting or develop its own program. Those institutions that develop their own programs may…
§__.42 CRA Data Collection for Lines of Credit
§__.42 – 3 Q: How should an institution report data on lines of credit? A3. Institutions must collect and report data on lines of credit in the same way that they provide data on loan originations. Lines of credit are considered originated at the time the line is approved or increased; and an increase is considered a…
§__.42 CRA Data Collection for Line of Credit Renewals
§__.42 – 4 Q: Should renewals of lines of credit be collected and/or reported? A4. Renewals of lines of credit for small business, small farm, consumer, or community development purposes should be collected and reported, if applicable, in the same manner as renewals of small business or small farm loans. See Q&A §__.42(a) – 5 Institutions that are HMDA…