MSA/MD and County Changes for the 2024 Reporting Year

On January 10th, the Federal Financial Institutions Examination Council (FFIEC), in conjunction with the Consumer Financial Protection Bureau (CFPB), announced that changes to Metropolitan Statistical Areas (MSAs) and Metropolitan Divisions (MDs) published by the Office of Management and Budget (OMB) on July 21, 2023, were being adopted for the 2024 reporting year. This update also incorporates the Connecticut County-Equivalent changes published by the US Census Bureau to the Federal Register on June 6, 2022.

The regulators did not do the industry any favors by announcing the adoption of these changes 10 days into the reporting year. All commercial geocoders were caught off guard by the sudden change, and are currently working to bring these changes in line for geocoding purposes, but to date none have published data yet. Financial institutions were directly affected as well since they need to create Facility-Based Assessment Area maps, however the Census Bureau, who is the caretaker of mapping data, does not plan to release updated mapping shapefiles until closer to the end of this year.

The changes were published in the form of "crosswalk" files that were subsequently updated on March 7th to incorporate all tract, county, and MSA/MD changes as well as census tract median income changes due to census tracts moving in and out of MSA/MDs, which directly affects the income level of the census tracts. RATA has taken these files as published by the FFIEC/CFPB and created the following updates:

1. Demographic Data for the 2024 reporting year has been updated, which includes: changes to census tracts and their corresponding income level; MSA/MD changes (removal of deprecated MSA/MDs and addition of new MSA/MDs); county changes (removal of deprecated counties in Connecticut and addition of county-equivalent planning divisions).
2. Census tract, county, and MSA/MD mapping shapefiles for the mapping component so that geographic areas can be created to provide correct Facility-Based Assessment Area maps for the 2024 reporting year in connection with the final rule regarding Community Reinvestment Act (CRA) changes published on October 24, 2023.

If you are a user of Comply on RATA Hosted Services (RHS), there is nothing you need to do to receive these updates, they will automatically be applied to your system by RATA personnel. If you are a user of Comply in an on-premise installation, you will need to undertake two updates. The Demographic Data will be provided through Auto-Update and the RATA support website. The mapping data changes that incorporate the 2024 geography changes will be provided solely through the RATA support website.

IMPORTANT NOTE:

Any geocoding that was performed from January 1st to present in the affected areas will fail edit checks once the updates have been applied to your system. This is expected, and will need to be addressed by the Comply user in a two-step process:

1. Update and correct invalid MSA/MD values by clicking the Global Set button on the Applications ribbon and selecting MSA/MDs. This will automatically correct any MSA/MDs that have changed to the new 2024 values.
2. All records geocoded in the state of Connecticut will need to be re-geocoded. This is accomplished by first filtering to all records in the state of Connecticut either by using the Original State Abbreviation of CT or the State Code of 09. Once in the filter of Connecticut records, click the drop-down of the Geocode button on the Applications ribbon and select Delete Filtered Geocodes. When given the choice, select All Geocodes, then acknowledge the warning when it appears. This will reset the geocodes for all the records in Connecticut so that they will re-export for geocoding when the next Geocode export is performed.