The vendor we use for HMDA/CRA compliance and geocoding appears to have different median income levels for our assessment areas than the current FFIEC est. MSA/MD median family income. We're still trying to get more information from the vendor on where their data is coming from but wondering if anyone has also run into this issue or any valid circumstances when they'd use any measure other than the FFIEC released data?

I assume you are referring to the new income class listings. The FFIEC posted the new 2024 tract income class listing about 3 weeks ago. It's derived from the realignment of the MSAs that was based on the OMB posting in July 2023 and made effective by the FFIEC on January 1, 2024. However, the FFIEC did not publish the new tract income classifications until recently. So it may be that your vendor has not caught up with the changes (although they should have!).

The new 2024 MSA median family incomes have been posted too (which are the denominator in the tract income class determinations). Is that what you are referring to?

Finally, the 2024 annual EMFI has not yet been posted by the FFIEC. Typically they publish those numbers in June when they release the annual demographic files.

Thanks Len, the discrepancies we're seeing are actually related to 2023 income information (at least in how it's being described), but I'm still waiting for more information from the vendor for how/why we'd use anything other than what the FFIEC published for 2023.