LARGE SELF-ASSESSMENT SELF-ASSESSMENT SELF-ASSESSMENT. Who would benefit from a CRA Self- Assessment? Why do a CRA Self-Assessment?
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1 LARGE INSTITUTION CRA Who would benefit from a CRA Self- Assessment? The Institution Small Bank Intermediate Small Bank Large Bank Strategic Plan Bank Wholesale or Limited Purpose Bank The Board of Directors/Bank Management 2 Why do a CRA Self-Assessment? Understand your bank s demographic profile Understand how your bank s products meet the needs of the community Identify areas of potential weaknesses in the CRA program Know what the examiners will find when they do your next CRA evaluation Status reports to the Board of Directors 3 1
2 What areas should be reviewed Assessment Area configuration/legality Draw a MAP!! Include branch hlocations Review marketing techniques HMDA data/cra data accuracy Can t accurately analyze your performance by using flawed data 4 Performance Context Develop demographic profile Consider talking to community groups or other community contacts t about area needs Determine if there is a need to develop products/services to meet needs Review Performance Evaluations for other similarly situated institutions 5 Performance Context (continued) Determine if your customer profile changed Determine if your business strategy changed Identify any constraints that may affect overall CRA performance Identify any other factors that may affect performance 6 2
3 Lending Test Volume of mortgage lending Volume of mortgage lending to LMI borrowers Volume of mortgage lending in LMI census tracts t (CTs) Volume of business lending Volume of business lending to businesses with gross annual revenues of $1 million or less Volume of business lending to businesses in LMI CTs Volume of farm lending (if applicable) 7 Lending Test (continued) Aggregate industry data In-out ratios Loan-to-Deposit ratios Market share/rank of HMDA and CRA lending Identify any gaps in performance. Reasonable or need a plan to address gaps? Marketing? Review loan products and compare to needs as determined in Performance Context review 8 Community Development Community Development (CD) Test Combination of CD Lending, Investments, Services Qualified Investments t Community Development Services Identify opportunities for CD activity within your assessment area Document responsiveness to community needs Innovative products 9 3
4 Public File Lobby Notices Know your evaluation cycle and type Review areas outside your assessment area Draw a map! Consider branch locations Determine weight of assessment areas Determine weight of products 10 Track performance by assessment area Consider marketing techniques Fair lending compliance critical to CRA performance CRA performance also affected by violations of other illegal credit practices (UDAP, Reg Z, etc.) 11 Your Performance Context is dynamic Don t wait until the evaluation to determine CD activity Develop ongoing tracking process If you identify weaknesses, develop a plan to address it 12 4
5 Make sure your Self-Assessment is realistic Be prepared with all request information Be available during the evaluation process to answer any questions that may arise. 13 Communicate with your examiners! Establish ongoing dialog throughout the evaluation process and between evaluations Be organized and detailed in your information to examiners You won t get credit for things the evaluation team is not aware of. 14 Questions? Sheila Steck Compliance Lead Expert, Central District sheila.steck@occ.treas.gov 5
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