Our bank has over 70 "assessment areas". However, when the OCC does their analysis and prepared the PE, they alway combine the areas, such as full MSAs, all the counties in a certain MSA, or groups of counties that are in close proximity that are non-MSA in a certain state. It seems to me that it would be better for us to combine our assessment areas to mirror the groups that the examiners use on the PE. Does anyone else do that. I am not talking about changing the counties, census tracts,or geographical area. I am talking about the way we group them for reporting and internal analysis purposes. Also, we are due for an exam at the end of this year. Is there any reason we can't go ahead and change them this year? Don't we just need to re-define them when we report? We keep growing and the number of assessment areas is getting out of hand the way we have it now. Please advise.

I recommend you group your AAs just as the OCC does. Compatability and comparability are important as you do your analysis prior to their visits.

Full MSAs with all the counties and then all rural non-MSA counties as one. This last one will be weird, but that is what the OCC does. My rural non-MSA AA is made up of non-congruent counties stretching over 300 miles north and south and 100 miles east to west. It is just a patch work of rural counties that when aggregated are about the same deposit size as some of my MSAs.

Therefore, the CRA expectations are just as high in this rural MSA.

And yes, you can re-arrange the assessment areas to this configuration at any time prior to the examination. It does make sense to set things up the way your regulator views the bank; then you can set your goals to the configuration against which you will be judged.