--- name: cra-assessment-area-mapper description: "Delineates and documents Community Reinvestment Act assessment areas from branch, deposit-taking ATM, and lending geography — producing compliant boundary definitions, demographic and credit-need profiles per area, low- and moderate-income tract summaries, and an examiner-ready documentation package. Use when defining, updating, or documenting CRA assessment areas for a bank or fintech, or preparing assessment area support ahead of an exam." argument-hint: "[institution-type] [branch-geography]" allowed-tools: ["Read"] --- # CRA Assessment Area Mapper ## Purpose Translate an institution's branch, deposit-taking ATM, and lending footprint into properly delineated CRA assessment areas — each documented with demographic composition, LMI tract distribution, and identified community credit needs — so the compliance team has defensible boundaries and examiner-ready support rather than a spreadsheet of ZIP codes. ## When to Use Invoke this skill when the user asks to: - Define or delineate CRA assessment areas for a bank or fintech - Update assessment areas after opening, closing, or relocating branches - Document demographic and credit-need data for existing assessment areas - Check whether current assessment area boundaries comply with Regulation BB / 12 CFR 25/228/345 - Prepare assessment area support ahead of a CRA examination - Reconcile lending activity outside currently defined assessment areas ## Inputs Required Before starting, collect: - **Institution type and CRA framework**: Bank (small / intermediate small / large) or fintech/ILC; regulator (OCC, FDIC, or FRB) - **Branch and facility locations**: Addresses or MSAs/counties for each main office, branch, and deposit-taking ATM - **Lending geography**: Where the majority of loans (by number and dollar) are originated or purchased — by county or MSA if available - **Deposit concentration**: Where deposits are drawn from, if the institution takes deposits digitally or beyond branch markets - **Existing assessment areas** (if any): Current delineations being reviewed or updated - **Metropolitan vs. non-metropolitan focus**: Whether markets are inside MSAs, nonmetropolitan counties, or both - **Data vintage**: Which census/FFIEC data year the analysis should reference If regulator or asset-size tier is missing, default to the large-bank rule framework and note the assumption; flag where small/ISB thresholds would change the analysis. ## Instructions ### Step 1: Establish the Delineation Standard Confirm the governing rule before drawing any boundaries. - Assessment areas must consist of one or more MSAs (or Metropolitan Divisions) or one or more contiguous political subdivisions — counties, cities, or towns. - They must include the geographies where the main office, branches, and deposit-taking ATMs are located, plus surrounding geographies where a substantial portion of loans is originated or purchased. - They may not extend substantially beyond an MSA or state boundary, may not arbitrarily exclude LMI geographies, and may not reflect illegal discrimination. - Note the 2023 modernized-rule considerations (facility-based and retail lending assessment areas) if the institution is subject to them, and flag which framework applies. ### Step 2: Map the Facility-Based Assessment Areas Build the core boundaries from physical presence. - List every main office, branch, and deposit-taking ATM with its county and MSA/MD. - Group contiguous political subdivisions around each cluster of facilities. - For each candidate area, state the boundary as a named list of counties (and MSA/MD where applicable) — not ZIP codes. - Verify the area does not bisect a county and does not exclude any LMI tract that would otherwise fall inside the boundary. ### Step 3: Test Lending Concentration Beyond Facilities Identify whether lending activity requires additional or expanded areas. - Compare where a substantial portion of loans is originated/purchased against the facility-based boundaries. - Flag any county or MSA carrying material lending volume but sitting outside all defined areas — this is a common exam finding. - Recommend whether to expand a boundary, add an assessment area, or document why the activity does not warrant delineation (e.g., diffuse nationwide lending for an internet-based institution). ### Step 4: Profile Each Assessment Area For every delineated area, build a data profile using FFIEC census and demographic reference data: 1. **Geography summary**: Counties/MSA included; total census tracts; count and percentage that are low-, moderate-, middle-, and upper-income; number of tracts with unknown income. 2. **Population and household data**: Total population; number of families; percentage of families by income category (low/moderate/middle/upper). 3. **Housing profile**: Owner-occupied vs. rental units; median housing value; housing affordability signal relative to area median income. 4. **Business profile**: Number of businesses; share of small businesses (GAR ≤ $1MM); indicator of small-business credit demand. 5. **Credit needs**: Identified needs synthesized from the LMI concentration, housing affordability gap, and small-business density — e.g., affordable home purchase/rehab lending, small-dollar business lending, financial access in underserved tracts. Present each profile in a consistent table so areas are comparable side by side. ### Step 5: Flag Compliance Risks and Gaps Surface issues an examiner would raise: - **LMI exclusion**: Any boundary that carves around low- or moderate-income tracts. - **Overextension**: Areas reaching substantially beyond an MSA or state line. - **Lending-outside-AA**: Material activity not captured by any area (from Step 3). - **Contiguity/geographic integrity**: Non-contiguous subdivisions or partial-county inclusions. - **Stale delineation**: Boundaries not updated after branch changes or a new census vintage. For each risk, state the specific area affected and the corrective action. ### Step 6: Assemble the Documentation Package Produce examiner-ready output: - Boundary definitions per area (named political subdivisions and MSA/MD). - Demographic and credit-need profile tables per area. - Compliance-risk register with corrective actions. - A one-paragraph delineation rationale per area explaining how it satisfies the Step 1 standard. ## Output Format - **Structure**: Delineation standard summary → assessment area boundary definitions → per-area profile tables → compliance-risk register → delineation rationale statements - **Length**: 1,000–1,500 words, plus one profile table per assessment area - **Format**: Structured document with tables for demographic/credit-need profiles and the risk register; prose for rationale statements - **Sections**: Governing Framework → Assessment Area Delineations → Area Profiles (one table each) → Lending-Concentration Check → Compliance-Risk Register → Delineation Rationales - **Tone**: CRA officer to examiner — precise, regulatory, cites the applicable standard; no marketing language ## Quality Checklist Before delivering output, verify: - [ ] Every assessment area is defined by named political subdivisions or MSAs/MDs — not ZIP codes - [ ] Each area includes the counts and percentages of low-, moderate-, middle-, and upper-income tracts - [ ] No delineated boundary arbitrarily excludes an LMI tract inside its footprint - [ ] The lending-concentration check explicitly addresses activity outside facility-based areas - [ ] The correct rule framework (small / ISB / large / modernized) is stated and applied consistently - [ ] Each area has a rationale statement tying it back to the Regulation BB delineation standard ## Notes - Delineation is a legal boundary exercise first and a data exercise second — get the political-subdivision and contiguity rules right before layering in demographics. - The most common exam criticism is lending concentration outside defined assessment areas; Step 3 exists specifically to catch this before an examiner does. - Internet-only and fintech deposit models complicate delineation — for these, document deposit and lending distribution carefully and address the modernized retail lending assessment area concept where applicable. - Always confirm the FFIEC census data vintage; assessment area income classifications shift when new census data takes effect, and stale profiles are a documentation risk. --- ## How to use this skill This file is a Claude Code skill in [Anthropic's standard format](https://docs.anthropic.com/en/docs/claude-code/skills) — markdown with YAML frontmatter at the top. **Installing in Claude Code:** - `~/.claude/skills//SKILL.md` — auto-loads in every session anywhere on your machine (recommended for skills you'll use across multiple projects) - `/.claude/skills//SKILL.md` — auto-loads only when working in that project (recommended for project-specific skills) Restart Claude Code or open a new session to register. **Using in Claude.ai, ChatGPT, Gemini, or other AI tools:** 1. 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