Success by JazE Edutech / Resource Kit
Resource Kit
A worksheet kit for branchless banks: map retail lending to counties, test the retail lending assessment area trigger, and build documentation to examination standards.
An online-only bank with no branches delineates no facility-based assessment area at all, because facility-based assessment areas attach to physical branch locations. Instead, a large branchless bank must define one or more retail lending assessment areas: whole counties where it originated at least 100 home mortgage loans or at least 150 small business or small farm loans in each of the prior two calendar years — a per-year count, not a two-year total — under the delineation definitions at 12 CFR 25.12 (OCC), 345.12 (FDIC), and 228.12 (Federal Reserve). The rule's condition that more than half of a loan category be made outside facility-based areas applies only to banks with branches, so a branchless bank satisfies it automatically.
Full written guide, sources, and FAQs
Online-only banks draw CRA assessment areas from where they lend, not where they branch. This kit walks through the county-level trigger screen, whole-county area assembly, and the documentation file behind them.
This resource helps readers connect how are assessment areas defined for online-only banks to classroom practice, standards-aware implementation, and responsible next steps for schools and sponsors.
Under the 2023 CRA final rule, an online-only bank defines its assessment areas from where it lends rather than where it sits. Facility-based assessment areas are tied to branch locations, so a bank with no branch network delineates none. Instead, a large branchless bank maps its retail lending to counties and must create one or more retail lending assessment areas wherever its originations cross the rule's loan-count thresholds. The rule applies those thresholds 'in each of the prior two calendar years' — a per-year screen, not a two-year total — under the delineation definitions at 12 CFR 25.12 (OCC), 345.12 (FDIC), and 228.12 (Federal Reserve). This kit turns that exercise into worksheets you can complete in an afternoon. The worksheets below run as a single sequence — the Branchless Delineation Lab — where each output feeds the next.
It is written for CRA officers, compliance analysts, and consultants at internet banks and branchless community lenders preparing for the 2023 rule's phased compliance dates. It also helps partnership teams understand why the assessment area file shapes how examiners read a lending footprint, and, under the modernized rule, why community development activity is now judged bank-wide rather than inside branch footprints alone.
The kit is a working packet, not a summary. Every worksheet feeds the next one: a bank-profile screen, a county-level trigger tally, an assembly plan, and a documentation checklist you can hand to internal audit or your examination support team. Worked scenarios show what the outputs look like for three different branchless lenders.
The Branchless Delineation Lab is a sequence of worksheets that switch on and off with your bank profile. Start with the Bank Profile Screen. Select whether your institution operates branches; when the branch count is set to zero, the facility-based assessment area panel switches off and the retail lending assessment area worksheet activates. That state change is the core lesson: without facilities there is nothing to surround, so delineation authority comes entirely from loan data.
Next, the County Trigger Tally lists every county where you geocoded originations. Enter counts for home mortgage loans and for small business or small farm loans separately for each of the prior two calendar years. Any county that clears 100 mortgages or 150 business loans in each of the two years flips its row to a trigger result, and the assembly sheet pulls it into a proposed retail lending assessment area automatically. Drop below the threshold in a later year and the row releases — the worksheet mirrors how the rule re-tests every cycle.
Finish with the Delineation File Checklist and save the outputs with your examination materials. If your totals stay below every threshold, complete the negative-screen page anyway: documenting that no county triggered is itself the deliverable. The kit keeps each county's tally tied to its dated source report so the file rebuilds cleanly next cycle.
Before you call the delineation file done, confirm every line below. The first items establish that the rule applies and was applied correctly; the rest protect the file under review. Keep dated copies of the underlying loan reports; a trigger that cannot be rebuilt from source data is a finding waiting to happen.
The scenarios below mirror the patterns a branchless lender hits most often. Read them before completing your own tally: the differences turn almost entirely on loan category mix and county concentration, not on headcount or deposit strategy. Each outcome is legitimate under the rule as long as the worksheet trail supports it.
This kit pairs with the 2023 CRA Final Rule explainer and the compliance-date lookup: read what changed, pin your dates, then complete the worksheets to produce the delineation itself.
If your question sits one step earlier — whether the CRA applies to your charter at all — start with the Coverage Gate Scoping Kit. If you are already counting loans, the small business loan reportability checker helps you decide which files belong in the small business tally before the trigger screen runs.
This kit is part of Success's CRA practice suite, and its outputs are built to slot directly into the linked tools: the delineation file you assemble here pairs with the compliance-date lookup for your phase-in calendar and with the reportability checker for the loan files feeding your county tally.
This kit is educational material for general planning purposes. It is not legal, compliance, financial, tax, or investment advice, and it does not predict how any regulator will evaluate a specific institution, delineation, or examination file. Community Reinvestment Act treatment depends on each institution's facts, the current rule text, and examiner judgment.
Thresholds, dates, and definitions referenced here come from the 2023 final rule and the agencies' regulations as published in the Electronic Code of Federal Regulations; those provisions can be amended. Confirm the current text for your regulator — OCC, Federal Reserve, or FDIC — and work with your compliance and legal teams before finalizing any assessment area delineation or examination submission.
Yes — under the 2023 rule, assessment areas come from lending rather than branches. A large bank without branches delineates retail lending assessment areas in any county where, in each of the prior two calendar years, its originations cross the rule's loan-count thresholds. Facility-based assessment areas apply only where there are branches to base them on.
The screen is a per-year count, not a two-year total. The delineation definitions — 12 CFR 25.12 (OCC), 345.12 (FDIC), and 228.12 (Federal Reserve) — require at least 100 home mortgage loans or at least 150 small business or small farm loans in a single county 'in each of the prior two calendar years.' The more-than-half-outside condition attaches only where a bank has facility-based assessment areas, so for a branchless bank it is satisfied automatically.
The bank delineates no retail lending assessment area for those counties. The operational task is to document the negative screen — the per-year counts for each of the prior two calendar years and the data cutoffs showing no county crossed a threshold — so the decision can be reproduced at the next examination.
Facility-based assessment areas are drawn around staffed banking facilities such as branches. An internet-only bank that operates no staffed facility has no location to build one from, so its delineation file rests entirely on retail lending assessment areas and the documentation behind them. A bank that keeps even one staffed banking office should map that facility separately before concluding it is fully facility-free.
The trigger screen runs against the two preceding calendar years of originations, with the thresholds measured per calendar year, so the answer can change every cycle. Counties that fall below the thresholds release, and counties that cross them must be added — which is why the kit ties every tally to a dated source report.
Under the 2023 rule, the community development financing test is applied to a bank's entire footprint rather than being confined to assessment areas. A branchless bank's partnerships are evaluated on the bank-wide record, while retail lending is evaluated through the assessment area framework this kit addresses.
Electronic Code of Federal Regulations
Electronic Code of Federal Regulations
Electronic Code of Federal Regulations
Federal Financial Institutions Examination Council
Federal Deposit Insurance Corporation
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