Now that the FFIEC has released the updated census tracts, I have a question as to how other banks deal with this data. Obviously we would update any incorrect data that has been entered into the system for 2022, but what about the data for tracts from prior years? There would be tracts that are no longer tracts according to the 2022 release. Do most banks leave that data based on the year it was obtained or update the data? Why or why not?

The data has already been submitted for prior years. Why would you think you need to change it?

I am thinking for pulling reports from our system not CRA reporting. Such as the number of loans originated in a specific census tract comparing volume from year to year. It would be a manual process. Just trying to think this through.

The decennial census tract changes do complicate CRA performance analysis. Essentially, pre- and post-Census 2020 data must be isolated and analysis of a bank's activity in each time period compared to the market activity in that time period.