Some bankers have been panicked by the publication of the new MSA list because the press release from OMB states, "The delineations of the statistical areas shown in the appendix's nine lists take effect immediately". They take effect immediately for government agencies, but the FFIEC has stated that they won't be applied to HMDA or CRA until January 1, 2014 when they will be applied to new loans from that date forward.
This does mean that next year you will need to review your Assessment Area delineations again (since AA boundaries are not supposed to "substantially" cross MSA boundaries). It also means that all census tracts' income classifications will need to be recalculated and many may change. So you will need to review that impact on your CRA performance standards (LMI tract penetration rates, revitalization/stabilization qualified areas, etc.) as well. It is impossible to monitor your CRA performance without knowing your "performance context" and this affects some of the most important performance context parameters.
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