GeoDataVision President Len Suzio announced the release of the free 2022 Census Tracts with Majority-Minority tract designations. "The FFIEC released these files 10 days ago and we at GeoDataVision are making available for free listings of the new 2022 tracts so bankers and the public can identify the new tract identities and those determined to qualify as "Majority-Minority" status based on a minority population that exceeds 50% of a census tract's total population. These are very important for Fair Lending analysis", said Suzio.
Free Bankers Tools
The long awaited 2020 CRA Aggregate & Disclosure Data was finally finally released last week, on December 21 by the FFIEC. GeoDataVision has now compiled the data into a variety of market reports that are invaluable for market analysis as well as regulatory compliance purposes.
GeoDataVision is pleased to announce the publication of its free online interactive map that identifies and displays Majority-Minority census tracts. The classification has been determined by using the minority population percentages (greater than 50%) for every census tract in the country as extracted from the FFIEC 2021 Census Demographics file. "We have used the standard definition of a Majority-Minority census tract," said Len Suzio, President of GeoDataVision.
Many bankers have not collected the GAR information for the PPP loans they have extended to businesses. While this has not been required by regulators it could jeopardize the recognition of many loans that would qualify for community development credit under CRA examination standards because to qualify for "economic development" a loan must pass both the "purpose test" (job preservation) and a "size test" (the borrower must have GAR <=$ million or must meet the SBA size standards in Part 121 of the SBA Regulations).
As you may know, certain activities in "Designated Disaster Areas" are eligible for Community Development credit. Any areas designated as Disaster Areas eligible for Public Assistance Types C-G (areas that are designated for only Types A and B assistance are not eligible).
The FDIC and the OCC have published a Notice of Proposed Rule-Making for the Community Reinvestment Act ("CRA"). The NPR contains radical changes that dramatically affect the CRA responsibilities of every bank. You need to know what the proposed changes are and you should contact the FDIC and/or the OCC about them before it is too late!
The proposed changes are dramatic and will affect all banks in big ways.
Every year we invariably consult for banks who have "lending gaps" in their Assessment Areas. In a surprising number of cases it turns out that some of the tracts are "underwater tracts". Most banks don't even know there are any underwater tracts in their Assessment Area. All they know is they never lend in some tracts (and if they do have loans in underwater tracts they may want to verify their geocoding!)
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Do you feel the pressure to reach impossible or ill-defined CRA Performance goals ? How you have constructed your Assessment Area may be your problem!
Many bankers are not aware that when they have AA's within one of the eleven "mega" MSA's they can designate any or all of the MSA as an AA. However, when examiners evaluate their bank's CRA performance the procedure is to break down the AA into Metro Divisions for performance evaluation purposes. Bankers who want to mimic regulatory examination procedures to help them anticipate their examination experience may want to break up their AA into multiple AA's when they are located within one of the 11 mega MSA's.