Skip to content
BOL Conferences
Thread Options
#2002702 - 03/19/15 06:41 PM Assessment area and LPO
Marmaduchess Offline
100 Club
Marmaduchess
Joined: Oct 2009
Posts: 175
Oregon Coast
We have opened a loan production office in an area that is outside of our CRA assessment area. Do we need to broaden our assessment area to include the census tract where the LPO is? Since this isn't a true branch (all the employee does is real estate loans), I'm not sure how to handle it. I have added it to the public file list of branches but I'm not sure even that is correct

Thanks

Return to Top
CRA
#2002790 - 03/19/15 09:19 PM Re: Assessment area and LPO Marmaduchess
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
It is not a branch. Loan volume could impact your in/out ratio at some point and you would then consider whether to expand your AA.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


Return to Top
#2002796 - 03/19/15 09:56 PM Re: Assessment area and LPO Marmaduchess
Marmaduchess Offline
100 Club
Marmaduchess
Joined: Oct 2009
Posts: 175
Oregon Coast
Thanks PR. So no on adding it to the list of branches at this point, correct? It just feels wrong not to include it somewhere in the file.

Return to Top
#2002810 - 03/19/15 11:28 PM Re: Assessment area and LPO Marmaduchess
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You can certainly add it in a separate section of the list clearly labeled as an LPO.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2002814 - 03/20/15 01:26 AM Re: Assessment area and LPO Marmaduchess
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
The LPO is not a deposit-taking branch but nonetheless provides services to your clients. In section 228.43 subsection 5 of the Regulation banks are asked to provide information about services provided through branches including "at its option, a bank may include information regarding the availability of alternative systems for delivering retail banking services (e.g., ATMs, ATMs not owned or operated by or exclusively for the bank, banking by telephone or computer, loan production offices, and bank-at-work or bank-by-mail programs)."

I would suggest including the information about the LPO and any alternative delivery systems by which your bank offers services to the public in the public file. Also, as suggested by another poster, keep an eye on the impact of lending volume outside your AA. If the LPO generates a lot of volume it could wreck havoc with your AA ratio.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top
#2002893 - 03/20/15 02:39 PM Re: Assessment area and LPO Marmaduchess
Marmaduchess Offline
100 Club
Marmaduchess
Joined: Oct 2009
Posts: 175
Oregon Coast
Len, when you say lending volume, are we talking about how many loans or loan amounts. The LPO is in a very affluent area ( our AA is more low to middle income) so each loan is many times larger than what we do in our AA.

And thanks Kaybee. I did list it separately.

Return to Top
#2002921 - 03/20/15 03:27 PM Re: Assessment area and LPO Marmaduchess
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Yes, he is speaking of your # and $ of loans and the effect that will have on your inside/outside ratio. You are going to have to monitor that and determine when it makes sense to bring that area into the AA (if you can) or find a way to counteract the negative impact that will likely occur over time.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2003210 - 03/22/15 09:57 PM Re: Assessment area and LPO Marmaduchess
B_F Offline
Power Poster
B_F
Joined: Nov 2006
Posts: 7,228
Cincinnati, OH
Originally Posted By: Cecile
Len, when you say lending volume, are we talking about how many loans or loan amounts. The LPO is in a very affluent area ( our AA is more low to middle income) so each loan is many times larger than what we do in our AA.

And thanks Kaybee. I did list it separately.


It's both. smile

Return to Top
#2003332 - 03/23/15 04:36 PM Re: Assessment area and LPO Marmaduchess
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
Keep in mind that when we are talking about loan volume we are talking about the loan volume measured under CRA, small business loans and small farm loans, and HMDA-reported mortgages. Sometimes if your bank specializes in a certain type of loan such as auto financing that would be included. In addition, you want to be aware of CD lending if you are an ISB or larger.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

Return to Top