MIB UPCOMING EVENTS 2024 January 30 Memberships Renewals Due February 9 MIB Board Meeting Great Northern Hotel Helena, MT March 14-17 ICBA Live Orlando, FL April 10 MIB Spring Board Meeting Firebrand Hotel Whitefish, MT April 28-May 1 Capital Summit Washington, D.C. July 17-19 Convention and Trade Show Hilton Garden Inn Missoula, MT SEPTEMBER 14 Griz vs. Morehead State Tailgate Missoula, MT OCTOBER 2-3 Women in Banking Conference Springhill Suites Bozeman, MT October 4 MIB Fall Board Meeting Springhill Suites Bozeman, MT October 5 Cats vs. Northern CO Tailgate Bozeman, MT October 15 Ag Conference Hilton Garden Inn Great Falls, MT CRA IMPACT MSAs affect the CRA compliance efforts of banks and thrifts, too. They come into play in drawing up an institution’s CRA assessment area (AA), as well as in the small business and small farm lending disclosure statements prepared by regulators annually for institutions reporting their data (all except for “small” retail banks and thrifts). The CRA rules require that an institution’s CRA AA generally consist of one or more MSAs or metropolitan divisions — using the MSA or metropolitan divisions boundaries that were in effect as of Jan. 1 of the calendar year in which the delineation is made — or one or more contiguous political subdivisions (e.g., counties, cities or towns). A CRA AA may not extend substantially beyond an MSA boundary or beyond a state boundary unless the assessment area is located in a multistate MSA. If a bank or thrift serves a geographic area that extends substantially beyond a state boundary, the bank must delineate separate AAs for the areas in each state. If a bank or thrift serves a geographic area that extends substantially beyond an MSA boundary, it must delineate separate AAs for the areas inside and outside the MSA. The regulators prepare annually, for each MSA and the nonmetropolitan portion of each state, an aggregate disclosure statement of small business and small farm lending by all institutions subject to reporting of that data (all except “small” retail banks and thrifts). Therefore, the redrawn MSA boundaries might have an impact on your institution’s CRA compliance. Each bank and thrift with the affected counties in its CRA AA should review its delineation to make sure that the changes do not require an adjustment to those delineations. If any adjustments are needed, they should be made by April 1 — when any updating of CRA public files must be accomplished (including the map of your CRA AA). The OMB Bulletin provides the six lists of statistical areas that are available electronically at the link stated above or from the OMB website at https://www.whitehouse.gov/omb/ information-for-agencies/bulletins/. The update, historical delineations and other information about population statistics are available on the Census Bureau’s website at https://www.census.gov/programs-surveys/ metro-micro.html. 22 Community Banker
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