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 previously or from the OMB website at 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 www.census.gov/programs-surveys/metro-micro.html. William J. Showalter, CRCM, is a Senior Consultant with Young & Associates Inc. (www.younginc.com), with over 35 years of experience in compliance consulting, advising and assisting financial institutions on consumer compliance and compliance management issues. He authors and edits compliance publications and articles for Young & Associates. He can be reached at wshowalter@younginc.com. 800.228.2581 MHM.INC Now more than ever people want self-service options. With our core integrated ITMs we can make this a reality both in the lobby and in the drive-up of your branch. SELF-SERVICE BANKING 10 NEBRASKA INDEPENDENT BANKER
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