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#1727288 - 08/03/12 06:19 PM
Whole county for assessment area
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Platinum Poster
Joined: Mar 2008
Posts: 808
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Right now we have 97 census tracts out of 371 in the county for our assessment area. Being it is so hard to get good loans, we have to take them when they come! Our office is in low to moderate area, but the customers are not borrowing money like they used to, plus it is getting harder to get them qualified! What is the thinking of taking in the entire county of 371 census tracts? How is that "looked upon"?
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#1727297 - 08/03/12 06:27 PM
Re: Whole county for assessment area
SUSANE1
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10K Club
Joined: Aug 2002
Posts: 34,318
under the Lone Star
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Favorably by the regulators...they prefer whole geographies and a county being preferable in their eyes....
_________________________
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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#1727311 - 08/03/12 06:40 PM
Re: Whole county for assessment area
SUSANE1
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Platinum Poster
Joined: Mar 2008
Posts: 808
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well that is good to know, I remember one exam where they critized the bank for wanting to take in the entire county. I feel that if we do take in the entire county in our assessment area, then we would be assurred of lending a majority of our loans in the assessment area.
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#1727397 - 08/03/12 07:40 PM
Re: Whole county for assessment area
SUSANE1
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Platinum Poster
Joined: Mar 2008
Posts: 808
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While I have your attention ! I am using a little program (hope to get a more sophisticated one soon)to try to see if we are lending the majority in our assessment area, etc.. and our participations purc and sold - the clerk entered them into {other lines)... not small business..... we are lacking in our loans to small busines within our assessment area. Advise?
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#1727414 - 08/03/12 07:51 PM
Re: Whole county for assessment area
SUSANE1
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Platinum Poster
Joined: Mar 2008
Posts: 808
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And hopefully my last question, the census tract that your record is the address of the borrower UNLESS the collateral is real estate, then you use the census tract of the real estate?
thanks!!!
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#1727421 - 08/03/12 08:01 PM
Re: Whole county for assessment area
SUSANE1
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Platinum Poster
Joined: Mar 2008
Posts: 808
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well the little program , since we entered the participations into a category of "other lines" and not "Small business".. it looks like we are lacking in the area of small busines lending.. and yes, they are outside the area! ugh - being participations..
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#1727478 - 08/03/12 09:13 PM
Re: Whole county for assessment area
SUSANE1
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10K Club
Joined: Dec 2000
Posts: 21,293
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For participations, look to the original size of the loan (and the collateral and purpose) to see if it qualified as a small business loan at the time it was originated by the bank that sold the participation to determine how to report, small business or other. Refer to the FAQs:
§ll.42(a)(2)—1: When an institution purchases a small business or small farm loan, in whole or in part, which amount should the institution collect and report—the original amount of the loan or the amount at purchase? A1. When collecting and reporting information on purchased small business and small farm loans, including loan participations, an institution collects and reports the amount of the loan at origination, not at the time of purchase. This is consistent with the Call Report’s and TFR’s use of the ‘‘original amount of the loan’’ to determine whether a loan should be reported as a ‘‘loan to a small business’’ or a ‘‘loan to a small farm’’ and in which loan size category a loan should be reported. When assessing the volume of small business and small farm loan purchases for purposes of evaluating lending test performance under CRA, however, examiners will evaluate an institution’s activity based on the amounts at purchase.
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#1727480 - 08/03/12 09:17 PM
Re: Whole county for assessment area
SUSANE1
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10K Club
Joined: Dec 2000
Posts: 21,293
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For geocoding, the bank can use the business address or the collateral address. It is up to the bank but consistency in reporting is the key. The CRA Guide and the FAQs provide instructions on the address to use (the FAQs tie this to the BSA requirement for a physical address, something I have been harping on to banks for quite some time.)
Loan Location Prudent banking practices dictate that an institution know the location of its customers and loan collateral. Therefore, institutions typically will know the actual location of their borrowers or loan collateral beyond an address consisting only of a post office box.
Many borrowers have street addresses in addition to post office box numbers or rural route and box numbers. Institutions should ask their borrowers to provide the street address of the main business facility or farm or the location where the loan proceeds otherwise will be applied. Moreover, in many cases in which the borrower’s address consists only of a rural route number or post office box, the institution knows the location (i.e., the census tract) of the borrower or loan collateral.
Once the institution has this information, it should assign a census tract to that location (geocode) and report that information as required under the regulations.
If the institution cannot determine the borrower’s street address, and does not know the census tract it should report the borrower’s state, county, MSA/MD, if applicable, and “NA,” for “not available,” in lieu of a census tract.
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#1736137 - 08/29/12 02:12 PM
Re: Whole county for assessment area
SUSANE1
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Platinum Poster
Joined: Feb 2010
Posts: 835
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Should the board annually approve the assessment area determination method the bank uses? Would senior management approval be sufficient?
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Live Like No One Else! CRCM
Opinions expressed are my own and do not reflect the views of my employer.
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#1736315 - 08/29/12 05:44 PM
Re: Whole county for assessment area
SUSANE1
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Power Poster
Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
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WW I am not sure any bank I've been affiliated with has even gone that far up. Usually it is the compliance/CRA group that decides and trains the loan department on what they expect of them. After all, CRA compliance has the end use of the data so they should get to make the rules. The loan dept and Sr. mgmt could care less. Besides if left to Sr Mgmt, they might say to use the address that makes the bank look the best, which would be a nightmare. (spoken from experience with a bank that did this)
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.
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#1741625 - 09/18/12 02:11 PM
Re: Whole county for assessment area
SUSANE1
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Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
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Our AA consists of whole counties. Is there a way to get what tracts are within the county without looking at the map?
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