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#1601764 - 09/09/11 05:03 PM CRA Assessment Area
Shera Offline
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Joined: Mar 2010
Posts: 22
Louisiana
When should a large bank re-assess their assessment area if the bank have plans to open more branches? Should the bank re-assess the assessment area before or after the new branches?

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#1601795 - 09/09/11 05:29 PM Re: CRA Assessment Area Shera
3-2-Go Offline
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East
I personally would wait until I had some data to base this descision on.

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#1601853 - 09/09/11 06:18 PM Re: CRA Assessment Area 3-2-Go
Pale Rider Offline
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under the Lone Star
There must be some data now available to management if they are thinking of opening de novo branches outside the exisiting AA.

Do you use whole counties as your AA Shera?

You wouldn't want to wait too long...as in getting the CRA pre-exam request list and having opened the branches without expanding the AA.
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#1602075 - 09/09/11 11:15 PM Re: CRA Assessment Area Shera
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
Originally Posted By: Shera
When should a large bank re-assess their assessment area if the bank have plans to open more branches? Should the bank re-assess the assessment area before or after the new branches?
Taking a look at where you are pulling deposits from and where you are lending can help to determine where you should put a new branch.

In terms of solely the AA, It would be good to assess a before and after picture so you can have a good picture of the effects of the added branches. If you are lending in one area outside the AA and adding branches in another you have to wonder why?
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#1602279 - 09/12/11 03:42 PM Re: CRA Assessment Area Pale Rider
Shera Offline
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Joined: Mar 2010
Posts: 22
Louisiana
We have whole counties.

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#1602286 - 09/12/11 03:52 PM Re: CRA Assessment Area Kathleen O. Blanchard
Shera Offline
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Joined: Mar 2010
Posts: 22
Louisiana
We know where we are going to add branch locations. What we would like to know is-----should we expand our assessment area before we open the locations or after we have had lending activity?????

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#1602384 - 09/12/11 05:31 PM Re: CRA Assessment Area Shera
Pale Rider Offline
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more art than science Shera...I would follow KB's advice and gather the numbers now before adding branches, expand the AA once the de novo branches are open, and then pick some dates after opening to see how you are serving the new AAs..
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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#1602764 - 09/13/11 01:59 PM Re: CRA Assessment Area Pale Rider
Shera Offline
New Poster
Joined: Mar 2010
Posts: 22
Louisiana
Thank you for your help.

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#1603865 - 09/15/11 04:33 AM Re: CRA Assessment Area Shera
Len S Offline
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Joined: Oct 2004
Posts: 1,971
Connecticut
I would definitely develop potential Assessment Area scenarios before finalizing branch sites. All too often management will make decisions without considering the CRA implications. I am not suggesting that CRA issues trump everything else, but management should definitely understand how different potential locations can affect AA delineation and thereby performance standards. I could tell you one story after the other when this has not been done and the bank has unknowingly made their CRA performance standards more difficult.
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