Six Fun Facts about Combined Statistical Areas

by | Oct 9, 2018 | blog | 0 comments

Combined Statistical Areas (CSAs) are defined in Community Reinvestment Act (CRA) Performance Evaluations (e.g., this one) as “a combination of several adjacent metropolitan statistical areas (MSAs) or micropolitan statistical areas or a mix of the two, which are linked by economic ties.” When describing regional markets for any product, like mortgages, media, etc., people often refer to CSAs, either explicitly or implicitly. Here are six fun facts about CSAs:

  1. The relationships between MSAs and CSAs are defined starting on page 120 of this 221-page PDF from Office of Management and Budget.
  2. There are 174 CSAs in the United States, including three in Puerto Rico. Of those 174, 66 (37.9%) are comprised of more than one MSA.
  3. HMDA data in LendingPatterns™ shows that the top eight CSAs account for 26.1% of the national mortgage market for 2017.

The top eight are, in descending order:

Los Angeles-Long Beach

New York-Newark

Washington-Baltimore-Arlington

Chicago-Naperville

San Jose-San Francisco-Oakland

Atlanta-Athens-Clarke-Sandy Springs

Dallas-Fort Worth

Boston-Worcester-Providence

First lien, owner-occupied apps only; micropolitan statistical areas, purchased loans, home improvement apps, and multi-family apps excluded.

  1. As explained by bank regulators in the July 2016 CRA Interagency Questions and Answers, more than one MSA in a CSA may be delineated as a single Assessment Area (AA).

A bank’s CRA performance is evaluated at the MSA level, rather than at the CSA level, using separate Median Family Incomes (MFIs) and other relevant information for each MSA. Also, the only way that banks can delineate an AA that  “extends substantially” across the boundaries of an MSA is if they stay inside the boundaries of a CSA.

  1. NCUA’s 2016 Field of Membership rule allows credit unions to apply to serve a CSA, as long as the CSA’s population is less than 2.5 million.
  2. A CSA has been used as a unit of analysis by regulators examining potential ECOA violations. See, for example, a 2012 consent order related to steering entered into by Wells Fargo and the US Department of Justice.

LendingPatterns™ can help banks make informed decisions about whether to expand into different portions of CSAs. You could be considering adding brick-and-mortar branches, tacking on a new AA, or stepping up your marketing in another MSA or Metropolitan Division within a CSA where you already operate.