When comparing peer HMDA data to bank data, is it done by tract or county?

I've never heard of anyone breaking it down to the tract level. In most cases, it's your overall performance you want to look at.

i'm thinking pct moderate-income tracts. With the commercial loans, the lowest level is county for peer data regardless of how many tracts you have in that county. Not quite a direct comparison, nor does it account for non-reporters.

We regularly analyze bank CRA performance and look at:
1 Market rank and market share aggregated for each and every reporting lender for your assessment area
2 Market rank and market share for all reporting lenders lending to LMI borrowers inside the assessment area
3- Market rank and market share of all HMDA lenders who originated loans inside LMI tracts within the assessment area
4- the percentage of market reported mortgages originated inside assessment area lmi tracts as a percentage of all assessment area mortgages (compared to your percentage)
5- the distribution of your loans among each and every tract inside your assessment area (the regs don't require you to lend in every tract inside your community but examiners are looking for unexplained "gaps in contiguous tracts. Therefore, you must be able to examine your lending down to a tract level)
If you need more info, please feel free to contact me.

While the lowest level of peer data is the county level as you indicated in your response, the aggregate data is available on a tract by tract basis. This would allow a precise calculation of the market penetration rates in the LMI tracts as well as the calculation of the market penetration rates with respect to lending to businesses with $1 million annual revenue or less. These are important performance benchmarks under CRA.