Consumer Compliance Outlook
FFIEC Announces Changes to Census Data Used for HMDA and CRA
On August 26, 2011, the Federal Financial Institutions Examination Council (FFIEC) announced that all Home Mortgage Disclosure Act (HMDA) and Community Reinvestment Act (CRA) data collected in 2012 must be geocoded using the new 2010 census tracts.1
Data collected in 2011 and submitted in March 2012 will still be geocoded using the 2000 census tracts. On a related note, on October 19, 2011, the FFIEC announced that the FFIEC census data file will incorporate data from the U.S. Census Bureau's American Community Survey (ACS). The FFIEC census data “are used to provide context to HMDA and Community Reinvestment Act (CRA) data.”2 According to the Census Bureau, the ACS is an ongoing survey that was fully implemented in 2005 after several years of testing. While the census data provide “counts of the population and their basic characteristics [such as] sex, age, race, Hispanic origin, and homeowner status,” the ACS data provide detailed “demographic, social, economic, and housing characteristics.”3
The FFIEC will use the 2010 five-year ACS data to update its base file annually and will refresh the base file every five years. Historically, the FFIEC census base file was updated every 10 years. “Implementation of the new data for consumer compliance and CRA examination purposes will occur in 2012, and the data will be utilized in the same manner that decennial data has been used in the past. In addition to the tract income data, the new base file will include updated race and ethnicity data.”4
Also on October 19, 2011, the FFIEC announced that it will calculate the annual median family income data that are published each June that were previously calculated by the Department of Housing and Urban Development. These data are also used for HMDA data compilation and CRA evaluations.