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Are your CRA performance standards unfair or unclear? Maybe it's because you inflated your own CRA requirements

Dear Banker,

I can't tell you how often I've heard bankers complain about "unfair" or "unclear" performance expectations. They don't seem to understand they set CRA performance standards when they delineate their Assessment Areas.  

The biggest CRA-related decision you will ever make is how you delineate your Assessment Area.

Why? Because how you define your market determines not only your results; it also is what defines your "performance context" - and it is performance context that drives performance standards.

Are there "underwater" census tracts in your CRA Assessment Area?




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!)

GeoDataVision Announces Summary of 2019 Community Reinvestment Act Tract Income Class Changes

 Compare Tract Inc Class Summary Tables

The FFIEC recently published the 2019 Census Demographic files that are the basis for the Community Reinvestment Act (CRA) tract income classifications.

    Thirty-three states plus the District of Columbia and Puerto Rico had tracts whose income class was changed.

  • Seventeen states had no tracts with income class changes
  • The states with the most tracts whose income class changed were New York and New Jersey
  • A total of 1,190 tracts had their income class changed from 2018 to 2019

For more information, contact Bob Suzio at 203-245-2750.