In my public file I have always used the FFIEC printout of each of my assessment areas, along with a map, to detail my assessment areas. . When you include all the tracts in an entire county, the print out does not list each track by number. Under that column the letters "NA" show. This has always been fine with prior examiners. I'm undergoing an exam right now and they are saying this is a (minor) violation becasue i didn't list out each tract in the county. anyone else ever have this issue?

We haven't had that issue yet, but in the prep items this same thing was discussed so we adjusted. Prior to this examination, no one had mentioned it.

You are to list all tracts; that has always been the requirement.

(6) A map of each assessment area showing the boundaries of the area and identifying the geographies contained within the area, either on the map or in a separate list;


Geographies are census tracts.

One of the confusing issues regarding census tracts for 2014 is the way the FFIEC has recognized "underwater tracts". In previous years the FFIEC had intended to omit underwater tracts knowing that they are nonsensical for CRA purposes. But owing to a misunderstanding about the numbering of those tracts the FFIEC inadvertently included some of the underwater tracts in its official tract listings prior to 2014.

I had communicated with the FFIEC about this because I wondered about the inconsistency. It turns out they had thought all underwater tracts were numbered 9900 and above (not including tracts 99999) but there are census tracts that are underwater that don't meet that criterion. The upshot is that the FFIEC decided to include all underwater tracts in its Census file for 2014 (I assume they will continue to do so in 2015). Officially, there are 366 such tracts based on the number coding, but there are other underwater tracts too. In any event, this means that there are counties with underwater tracts included in the FFIEC official tract listings that are going to be included in your Assessment Area. You should be aware of those tracts because there are no demographics associated with them and there should be no lending either (but a bank that mistakenly geocodes loans to one of those tracts would have reported such loans in its annual HMDA or CRA filing). Any such tracts would be numbered 990000 to less than 999999