2010 Census Impacts CRA and Fair Lending Approach
The Federal Reserve announced that the 2010 census data will be released on Friday, June 29th. All banks and regulators will be required to use the new data for CRA, HMDA, and Fair Lending immediately. The Federal Reserve also provided additional guidance on the usage of 2010 Census Data in CRA Examinations. The guidance was updated and detailed on the Federal Reserve’s Outlook Live Webinar on Thursday, June 21st.
The Federal Reserve Board reviewed their guidance on the usage of 2010 census data. Below are a few of the highlights from the call:
It was announced that the FFIEC will release the updated 2010 Census demographic file, including population and housing characteristics, on Friday, June 29th
Going forward, demographic updates will occur every five years, instead the every ten years as was previously the case.
The number of census tracts increased from 66,309 (2000 census) to 74,002 (2010 census). Almost 19,000 tracts were either split, merged, or some other combination. Evidence of this change can be demonstrated by a few data points:
Census Tracts – Downward Movement: 15% of the 2000 Census Middle-Income Tracts are now LMI (low to moderate income) tracts.
Loans (2010 Lending) – Downward Movement: 10% of the loans from the 2000 Census Middle Income-Tracts are now in LMI tracts.
Branches – Downward Movement: 15% of the branches located in 2000 Census Middle-Income Tract are now in LMI tracts.
The Bottom Line: With the June 29th release, there is a large probability that the census tracts inside your Assessment Area have changed. According to the consumer affairs letter CA 12-4: “CRA assessment area designations will be reviewed during the course of an examination to ensure that the bank adequately adjusted its assessment area(s) to account for differences in census tract delineations based on the new 2010 census data.” Therefore, financial institutions will need to evaluate their Assessment Area(s) to be sure you are not excluding any tracts. CRA performance (loan, investment or service) in 2010 and 2011 should use the 2000 census information. CRA, HMDA, and Fair Lending analysis performed during 2012 (or beyond) should be assessed using the 2010 data.
How did these massive changes affect your assessment area?
TRUPOINT Partners offers a cost effective and efficient way to deal with these changes. We can help you with CRA maps, updating your assessment area, geocoding to 2010 tracts, and provide updated demographic reporting. CRA and Fair Lending compliance does not have to be time consuming or difficult. Request a free sample today.