Examiners apply several different benchmarks. The standards are derived from demographic data and credit market data as follows:
1- the relative distribution of LMI tracts as a % of all AA tracts
2- the relative distribution of owner-occupied housing in AA LMI tracts
3- the reported penetration rates of other lenders in the HMDA and CRA data pertaining to the Assessment area
4- the relative distribution of small businesses across AA LMI tracts
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