How do most of you plan to identify the loans that fall into the tracts that are distressed/underserved/disaster areas? To date, we have only 'geo-coded' loans that are on our CRA / HMDA / CDL register, not ALL loans in our portfolio. Because of this expanded requirement, we are considering the purchase of Geo-Pro. Any suggestions?

We geocode all loans. If you do not, how do you do internal analysis of your inside/outside ratio?

we base our analysis on the information from our HMDA / CRA registers, assuming that they are a representative sample of our entire portfolio.

That may not be a real good assumption. If you are only reporting Small Business/Farm loans. Then locations where that type of active may be, could be geographically centeralized into a business district, or rural area where other consuner type borrowers do not reside.

Some HMDA activity may be where one or two new tract development are located and not be representative of your total geography or assessment area.

You may not be getting broard loan distribution data by using just the CRA SmallBusiness/Farm and HMDA data.

HMDA is reporting where someone is going and not always where they are.

We geo-code 100% of our loans. For many of the reasons above and more.

We recommend to all our community bank clients that they tract all their non-reportable loans as well as CRA and HMDA data. This means they geo-code all the non-reportable loans and classify the loans consistent with the Fed CRA codes. This allows a bank to evaluate the impact of these portfolios on CRA performance and to determine if they should exercise their elective to include them in a CRA PE. Once you have the system set up it doesn't add that much time or cost to your CRA program. It's one of those situations you should take advantage of.
When the data is uploaded to our company for evaluation we will look at all loans (reported and non-reported) and advise our clients about how each portfolio affects performance according to the specific lending tests. We will assign the proper tract classification (income class, underserved, etc) as long as the client has properly assigned tract numbers. Alternatively, we will geo-code records for the client and append tract classifications to all records. There are many programs and services that give you lots of choice in this area.