Looking for advice on what is industry standard for defining your peers. Do you base your decision on HMDA or CRA information? I've been looking at CRA/HMDA market share and researching potential peers based on their depository market share. Problem is that my bank doesn't show up in one of our markets when I base my analysis on HMDA. Anywho, just trying to determine the best methodology and I would appreciate input.

I feel like this is one of those subjects that doesn't have a good answer - well all of compliance is like that I guess. However, I heard at a conference from a consultant (I believe it was the Marquis conference last year) that for HMDA, include lenders who make 50% to 150% of your number of HMDA loans in your AA (if you make 1000 HMDA loans, include banks who make 500 through 1500). For us, that worked 2014 but I feel like that could lead to a pretty big range for some banks. And we have an expanded AA now so we'll see how that shakes out once 2015 data is released. Prior to 2014, it was determined by our bank and I felt like that wasn't objective at all - some people viewed local banks as competitors when they really weren't when you looked at the numbers.

My two cents...

We want to measure ourselves against our peers and since we are a large bank now I would think it beneficial to do so with CRA data rather than HMDA. We use Centrax which is put out through Marquis and they have a really good "Defining your Peers" training as mentioned above. They really push using HMDA data because more banks report for this but I don't think you can truly measure yourself this way if you are a large bank doing this for CRA purposes.

Our problem with CRA peers is a lot of the banks we think are peers do not report CRA so it makes it more challenging. I don't have a good answer for the CRA side.

I'm going through this struggle as well. In the last few years we went from four $500 million dollar banks scattered across 3 states to one $2 billion dollar bank looking at being a data reporter and examined as a large bank starting next year. I'm considering comparing banks in the majority of our AAs (despite asset size) more so than similar asset size banks in our headquartered area. Thoughts?

You can choose different peers for HMDA and CRA if nothing seems to fit right. I chose those closest in asset size, branches and foot print. Even if the footprint isn't the same, find one that has the same regional challenges if possible. For asset size it doesn't necessarily have to be very close but think under 1B; 1-5 B; 5-10B and it might make it easier to find someone relatively similar.