As many of you know the OCC has adopted the concept of "deposit-based" assessment areas. The FRB and the FDIC are also considering adopting the deposit-based AA concept and the FRB has issued an ANPR including seeking comments about deposit-based AA's.

No one including the federal regulators knows how depositors are geographically dispersed because all information collected by the regulatory agencies is based on the branch location, not the depositor's location. There is no empirical data currently available.

Accordingly, GeoDataVision has undertaken to conduct a study wherein we will geocode bank deposits based on the location of the depositor. If you would be interested in participating in the project please click here to learn more: Depositor location project for CRA Assessment Area Study

Many banks geocode their deposits and analyze them already. It's certainly never been required for banks, however, it is a best practice.

TRUPOINT Partners has always done this, and since we were acquired by Ncontracts, we continue to provide this service at no additional charge to all of our CRA Analytics customers.

I am really surprised by Mike P's response. I've been working with hundreds of community banks for 26 years and I have never encountered even one banker who had geocoded their deposits, although many had expressed interest in doing so.

I am curious as to how many BOL readers geocode their deposits. If anyone reading this post would respond by indicating they do or don't geocode deposits I would be curious.

Regarding TRUPOINT clients, Mike do you know how many actually use the geocoding tool for their deposits and analyze the results? Too often I've found bankers who subscribe to sophisticated software but who barely touch the capabilities within the software. If you've found that many of your clients use the geocoding engine for deposit analysis, have many used the tool for the purpose of determining how the new deposit-based AA rules may affect them?

We are a TRUPOINT customer and while I'm sure we don't use the software to its full capabilities, we do look at the geocoding of our deposits. Primarily we review the deposit information to see if we are missing lending opportunities in any areas. Our existing AA covers a vast majority of our deposit activity, so a change to a deposit based AA wouldn't be an issue for us.

TMatt87- you have given an interesting response. Thank you.

How do you identify missing lending opportunities with deposit data location? I can see how you could match deposit owners with borrowers to determine if you have depositors who don't borrow, but how does the geographic component of a deposit play a role in identifying lending opportunities?

We look at LTD ratios in our various AAs or counties. If we have low a low LTD in a particular area, we may look to increase marketing for loans, hire additional lending staff, etc. Basically, if we see significant deposit activity in an area, we would expect to see lending as well.

We're an ISB but will be moving down to a small bank when the new threshholds take effect. We have geocoded our deposit accounts using Centrax in the past. Like Matt we also analyze our LTD for all of our AA's. We have a significant military population so I suspect we might be close to needing a deposit-based AA. We will continue to use Centrax to analyze our deposit locations.