CRA Question

The banks primary lending area comprises of 4 Counties. Three of these counties are not in our MSA, nor do we have offices in those counties. These three counties are within a mile of our location. We are in a MSA/county that is extremely large. but we only delineated 6 census tracts within our MSA as our Assessment Area.
I am looking at HMDA 2020 loan data- within and outside our AA. 55% of our lending for these loans were outside of our AA in 2020. Should the Bank's primary lending area and the AA match? How would we expand our AA into an MSA where we have no offices.

How would it be determined that you are meeting the needs of your assessment area, when the data shows that 55% of loans made in 2020 is outside of the AA. Do you look to the whole loan portfolio of loans made in the AA verses loans outside of the AA? I'm new to CRA and am confused . Was looking for direction.

Back in the day when I was a bank examiner, I would have questioned the assessment area delineation if more than half the loans were made outside of the assessment area.

Can a bank expand its AA into a MSA in which they have no offices?

Have you reviewed CRA regulation related to delineation of assessment area? If you are FDIC, look at part 345.41.