Is it a regulatory requirement to perform a needs assessment of the communities in the Assessment area?

Perhaps only in a round about way, but how would you know if your bank has met the needs of the community if you don't know what they are......

No - although the Q&A's encourage the development of a Community Needs Assessment, there is no requirement. We encourage our clients to develop a CNA because it can capture valuable performance context information and help put a bank's performance into better context.

The requirement and the need are two different things. Small community's with small banks likely have a good idea based on borrower's requests and involvement in the community as a whole. Larger banks in larger areas may need more probing information.

Also ask yourself what happens when your examiners talk to community leaders, businesses and residents and ask if your bank is meeting the needs, what will they hear, and how is your bank doing at meeting that metric?