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#1877159 - 12/09/13 07:40 PM CRA Assessment Area- Adding County/Branch
Jil Wurzburg Offline
New Poster
Joined: Mar 2011
Posts: 17
Hello- During 2013, we opened a branch in a county that was not originally included in one of our assessment area. We are adding this county to an existing assessment area. Do we only count loans in this assessment area from the date the branch opened ( May) or do we count all loans made in this county for 2013?

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CRA
#1877166 - 12/09/13 08:00 PM Re: CRA Assessment Area- Adding County/Branch Jil Wurzburg
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 1,966
Connecticut
The loans would be reported (if you are a CRA reporter) within your micro data file for the entire year (including anywhere you extended loans). When you are examined the examiners won't distinguish loans made before or after the area was annexed. They will, however, take that information as a performance context factor when evaluating your performance. So when you are self evaluating your performance be sure to include the "before and after" loans and temper your judgment with the fact that lending results may have been affected by the branch opening.It's a best practice to document your performance observations and explanations and present them to examiners as part of the performance context. It will impress examiner that you are so diligent and thorough (and thoughtful too).
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#1877630 - 12/11/13 01:31 PM Re: CRA Assessment Area- Adding County/Branch Jil Wurzburg
Jil Wurzburg Offline
New Poster
Joined: Mar 2011
Posts: 17
That is what I thought but I wanted to verify this, thank you so much for your help!

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