Objectives Upon completion of the CRA overview, you should:
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1 CRA Basics
2 Objectives Upon completion of the CRA overview, you should: Understand the purpose of the CRA; Understand terms and definitions under the CRA regulation including bank exam types Be generally familiar with the technical requirements of the regulation; Understand the CRA ratings 2
3 Purpose of CRA Encourage banks and thrifts to help meet the credit needs of their entire communities Including borrowers of different income levels and businesses/farms of different sizes Including low- and moderate-income neighborhoods, certain non-metropolitan middle income geographies or designated disaster areas Consistent with safe and sound operations 3
4 Definitions Geography Median Family Income Low- and Moderate-Income (LMI) Assessment Area (AA) Delineation Performance Context Community Development Primary Purpose 4
5 Geography Geography: a census tract delineated by the United States Bureau of the Census in the most recent decennial census MSA: metropolitan statistical area as defined by the Office of Management and Budget (OMB) MD: metropolitan division as defined by OMB Nonmetropolitan area: area not located in an MSA 5
6 Median Family Income An annual income figure for which there are as many families with incomes below that level as there are above that level Area Median Income (AMI) means: The median family income for the MSA or MD, if a person or geography is located in an MSA or MD The statewide nonmetropolitan median family income, if a person or geography is located outside an MSA or MD 6
7 Low- and Moderate-Income (LMI) Low-income = an individual income or tract income that is less than 50% of the AMI Moderate-income = an individual income or tract income that is at least 50% and less than 80% of the AMI Middle-income = an individual income or tract income that is at least 80% of AMI but less than 120% of AMI Upper-income = an individual income or tract income that is equal to or greater than 120% of AMI 7
8 True or False Median family income includes all households. False 8
9 Assessment Area (AA) Delineation Must consist generally of one or more MSAs or MDs, or one or more contiguous political subdivisions such as counties, cities, or towns, and Must include geographies where an institution has its main office, branches, deposit taking ATMs as well as surrounding areas in which it has originated or purchased a substantial portion of its loans 9
10 Assessment Area Delineation Adjustments to AA(s) May adjust the boundaries to include only that portion of a political subdivision that the institution can reasonably be expected to serve 10
11 Assessment Area Delineation Limitations on Delineation Must include only whole geographies Must not reflect illegal discrimination May not arbitrarily exclude LMI geographies Generally, may not extend substantially beyond an MSA or state boundary 11
12 Performance Context A broad range of economic, demographic, and institution- and community-specific information that an examiner reviews to understand the context within which an institution s record of performance should be evaluated. 12
13 Community Development Affordable housing for low- or moderate-income (LMI) individuals Community services for LMI individuals Activities that promote economic development by providing financing for small businesses or small farms Activities that revitalize or stabilize LMI geographies, distressed or underserved non-metro middle-income areas, or designated disaster areas. Activities that support, enable or facilitate projects or activities that meet eligible uses criteria described in Section 2301(c) of the Housing and Economic Recovery Act of 2008 (HERA) and are conducted in designated target areas identified in plans approved by HUD in accordance with the Neighborhood Stabilization Program (NSP) 13
14 Primary Purpose In order to receive consideration under the CRA, loans, investments, and services must have a primary purpose consistent with the definition of community development 14
15 Exam Types Small bank Intermediate small bank (ISB) Large bank Wholesale and Limited Purpose Strategic Plan 15
16 Small Bank Banks with assets under $280 million Lending Test: 1. Loan to deposit ratio 2. Lending in and out of the assessment area 3. Distribution of loans by geography 4. Distribution of loans by borrower income 5. Responses to complaints 16
17 Intermediate Small Bank (ISB) Banks with assets of at least $280 million and $1.122 billion Evaluated under the traditional small bank lending test PLUS a community development test CD activities should be responsive to community needs 17
18 Large Bank Assets of $1.122 billion or more Holding company not relevant Exam criteria: Lending Investments Services 18
19 Evaluations An ISB bank must be rated Satisfactory on BOTH the traditional small bank lending test AND the CD test in order to achieve an overall Satisfactory rating Any small bank (including an intermediate small bank) may opt to be evaluated under the large bank test 19
20 Technical Requirements CRA Public Notice Public File Delineation of Assessment Area 20
21 CRA Public Notices Must be displayed in the public lobby of each of its offices Details the public s right to review the institution s file and CRA-related comments
22 True or False The public notice is the same for the main office and each branch. False 22
23 Public File Full file At the main office At one office in each state Limited file at branch locations Provide all information relative to the branch s assessment area within five days of request 23
24 Public file for all institutions All written CRA related comments for the current year and two previous years The most recent public evaluation List of all branches - address and geographies List of services Map of Assessment Area(s) Last two years HMDA Disclosure Statement 24
25 Public File - Additional Requirements for Small Institutions Loan to deposit ratio for each quarter of the prior calendar year Information required by other institutions if it has chosen to be evaluated under the lending, service and investment tests 25
26 True or False The public file varies depending upon the size and other characteristics of the financial institution. True 26
27 Overall Ratings Outstanding Satisfactory Needs to Improve Substantial Noncompliance Ratings roll-up 27
28 Overall Ratings Large Bank Component ratings assigned a numerical value Composite rating is the sum of the numerical value of the component ratings Must receive at least a Low Satisfactory on the lending test to get an overall rating of Satisfactory or better 28
29 Public Evaluation Prepared by the agencies Exit discussion with Mgmt Exam completed and final ratings assigned and discussed with Mgmt Published on Agencies, FFIEC web site. Made available to the public on request 29
30 Why are CRA Ratings Important? Regulators must take into account the banks record of helping to meet the community credit needs when considering any corporate or licensing action. Examples include: branching, mergers, acquisitions, consolidations 30
31 True or False To receive an overall Satisfactory rating the bank can receive a Needs to Improve on the lending test if it receives an outstanding on the investment and service tests. False 31
32 True or False Evidence of discriminatory or other illegal credit practices adversely affects the evaluation of a bank s CRA performance. True 32
33 Resources Interagency Questions & Answers on Community Reinvestment March 11, Supervisory Agency Community Reinvestment Act Examination Handbooks Supplemental Interagency Procedures Intermediate Small Bank issued in 2005 Small Bank, Large Bank, Limited Purpose, and Strategic Plan issued in 2006 OCC Large Bank Examiner Guidance, December 2000 OCC Bulletin Performance Context Supervisory Agency Community Affairs Departments HMDA data, CRA data, geocoding/mapping system, rate spread calculator, links to CRA Performance Evaluations Deposit market share data, list of branches, Bank Call Reports Employment/unemployment data 33
34 Questions 34
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GENERAL INFORMATION. INSTITUTION'S CRA RATING: This institution is rated "Satisfactory."
GENERAL INFORMATION The Community Reinvestment Act (CRA) requires each federal financial supervisory agency to use its authority when examining financial institutions subject to its supervision, to assess
PUBLIC DISCLOSURE. May 9, 2005 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION COMMUNITY BANK & TRUST RSSD #
PUBLIC DISCLOSURE May 9, 2005 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION COMMUNITY BANK & TRUST RSSD # 957757 100 SOUTH WOOD STREET, P.O. BOX 400 NEOSHO, MISSOURI 64850-1819 Federal Reserve Bank
PUBLIC DISCLOSURE. February 7, 2011 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. Webster Bank, National Association Charter Number: 24469
O LARGE BANK Comptroller of the Currency Administrator of National Banks Washington, DC 20219 PUBLIC DISCLOSURE February 7, 2011 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Webster Bank, National
PUBLIC DISCLOSURE. September 27, 2004 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. BPD Bank RSSD No
PUBLIC DISCLOSURE September 27, 2004 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION RSSD No. 66015 90 BROAD STREET NEW YORK, NEW YORK 10045 Federal Reserve Bank of New York 33 Liberty Street New York,
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE February 1, 2016 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION FNBC Bank RSSD# 100843 636 Ash Flat Drive Ash Flat, Arkansas 72513 Federal Reserve Bank of St. Louis P.O. Box 442 St.
PUBLIC DISCLOSURE. September 13, 1999 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. BPD INTERNATIONAL BANK RSSD No
PUBLIC DISCLOSURE September 13, 1999 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION BPD INTERNATIONAL BANK 152 West 57 th Street Carnegie Hall Tower, 5 th Floor New York, NY 10019 FEDERAL RESERVE BANK
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT
PUBLIC DISCLOSURE March 31, 2014 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION First Bank & Trust RSSD# 2333298 820 Church Street Evanston, IL 60201 Federal Reserve Bank of Chicago 230 South LaSalle
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Mizuho Bank (USA) RSSD No. 229913 1251 Avenue of the Americas New York, NY 10020 FEDERAL RESERVE BANK OF NEW YORK 33 LffiERTY STREET
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE August 17, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Midland States Bank RSSD #773247 133 West Jefferson Street Effingham, Illinois 62401 Federal Reserve Bank of St. Louis
COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE August 23, 1999 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Bank of Cairo and Moberly RSSD# 833646 27 E. Rollins Street Moberly, Missouri 6527-2 Federal Reserve Bank of St. Louis
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE May 09, 2016 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION The Huntington National Bank Charter Number 7745 17 South High Street Columbus, OH 43216 Office of the Comptroller of the
CRA Manual September 2007
CRA Manual September 2007 National Community Reinvestment Coalition * http://www.ncrc.org * 202-628-8866 Table Contents Acknowledgments 3 Introduction 4 Summary CRA & How Public Can Be Involved 6 Outline
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE September 6, 2016 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Valley National Bank Charter Number 15790 615 Main Avenue Passaic, NJ 07055 Office of the Comptroller of the Currency
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE January 6, 2014 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION LegacyTexas Bank RSSD Number: 913267 5000 Legacy Drive Plano, Texas 75024 Federal Reserve Bank of Dallas 2200 North Pearl
November 20, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. 60 Wall Street New York, New York 10006
PUBLIC DISCLOSURE November 20, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION DEUTSCHE BANK TRUST COMPANY AMERICAS RSSD No. 214807 60 Wall Street New York, New York 10006 Federal Reserve Bank of
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PUBLIC DISCLOSURE May 7, 2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION RSSD #604024 95 West 4 th Street Minster, Ohio Federal Reserve Bank of Cleveland P.O. Box 6387 Cleveland, Ohio 44101-1387
COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE May 18, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION RSSD No. 645317 473 Broadway Saratoga Springs, New York 12866 Federal Reserve Bank of New York 33 Liberty Street New York,
PUBLIC DISCLOSURE. June 4,2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. Green Dot Bank, DBA Bonneville Bank RSSD #243375
PUBLIC DISCLOSURE June 4,2012 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Green Dot Bank, DBA Bonneville Bank RSSD #243375 1675 North Freedom Boulevard, 84604 Federal Reserve Bank of San Francisco
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE August 25, 2003 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION ORANGE COUNTY TRUST COMPANY RSSD 176101 212 Dolson Avenue Middletown, New York 10940 FEDERAL RESERVE BANK OF NEW YORK
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE April 11, 2011 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION The Hocking Valley RSSD ID #230610 7 West Stimson Athens, Ohio 45701 Federal Reserve of Cleveland P.O. Box 6387 Cleveland,
PUBLIC DISCLOSURE COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
PUBLIC DISCLOSURE February 17,1998 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Chemung Canal Trust Company 2362400 P.O. Box 1522 One Chemung Canal Plaza Elmira, New York 14902-1522 Federal Reserve