We are an ISB $890 million bank (four branches) within a very small footprint. All of our branches and deposit taking ATMs (DTATMs) are in the same County; none of our branches nor DTATMs are in an MSA. As such, we are not a HMDA reporter. Our current assessment area is the one county in which we are located and one additional census tract from a neighboring county. Neither that additional tract (nor the county in which it resides) contains an MSA; nor do we have a branch or any ATMs in that additional tract.
We are opening a Loan Production Office (LPO) in another non-contiguous county. This LPO will also include a deposit taking ATM at the same location. The location of this office/ATM is located in an MSA. While we have high hopes for this office, we are not exactly sure how much activity this office will generate and not sure of which surrounding geographies this office will end up serving. We do know that we will not be serving the entire MSA; the area is just too large and far reaching to be served by this new LPO.
Since we will not be opening accounts or accepting deposits within the LPO, we do plan to begin opening deposit accounts online.
I understand that we now must include the geography of the LPO in our assessment area.
Here are my questions:
• Are we taking a correct stance to, at the outset of this location opening up, include just that geography in our AA and to track & monitor our lending activity and modify our AA accordingly if we find a substantial portion of our lending is happening in other geographies
• Should we be tracking the geographies from which the new online deposit accounts are being received? I believe we should but I’m getting some push back that isn’t necessary. I’m not convinced so I’m reaching out for some opinions/guidance.
Thank you for any replies.
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