Typically, hmda lending performance is initially rated based off the assessment area market demographics. When looking at LMI tract performance, the owner-occupancy rates are the benchmark. Performance context issues may increase the initial rating, if warrented. Due to the financial crisis, the foreclosure crisis, and high unemployment rates; the opportunities to hit the 2000 census market demographics is extremely difficult and performance ratings are poor even after performance context issues are considered. I was wondering if any other institutions are using alternative benchmarks to determine more accurate ratings of lending performance, and if so, what are they?