A bank must first be designated as limited-purpose or wholesale before it can be evaluated under that standard
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- Lesley Horn
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1 Definitions Limited Limited-Purpose Purpose A bank that offers only a narrow product line (such as credit card or motor vehicle loans) to a regional or broader market Wholesale Wholesale A l Ab bank kth that ti is not ti in the business of extending home mortgage, small-business, small-farm, or consumer loans to retail customers
2 A bank must first be designated as limited-purpose or wholesale before it can be evaluated under that standard
3 To receive such a designation the bank must file a written request at least three months prior to the proposed effective date of the designation
4 Such a designation remains in effect: o Until the bank requests revocation of the designation Or o Until one year after the regulator notifies the bank it has revoked the designation
5 Frequency of Examinations o Depending on your rating, you will typically be examined every one to three years o Designated institutions are typically on a large institution cycle o Talk to your regulator if you have questions about this
6 Current number of institutions with FDIC 3 Federal Reserve 6 OCC 34 OTS 6 Total 49 the designation
7 A designated bank s record of meeting the credit needs of its assessment area(s) under the community development test is assessed through:
8 Its community development lending Its qualified community development investments Its community development services
9 Community Development means Affordable housing for LMI individuals Community services targeted to LMI individuals Activities that promote economic development by financing farms and businesses meeting certain size limits Activities iti that t revitalize or stabilize: LMI geographies Federally designated disaster areas Distressed or underserved nonmetropolitan MI geographies
10 Performance Criteria The number and amount of community development loans (originated or purchased), qualified investments, or community development services The use of innovative or complex qualified investments, community development loans, or community development services Responsiveness to credit and community development needs
11 Indirect Activities At the bank s option, will consider: Qualified investments or community development services of an affiliate (if not claimed by another institution) Community development lending by affiliates, consortia, and third parties (if not claimed by another institution, investor, or participant)
12 Inside Assessment Area(s) Will consider all qualified investments, community development loans, and community development services that benefit bank s assessment area(s) or a broader statewide or regional area
13 Outside Assessment Area(s) Will consider qualified investments, community development loans, and community development services that benefit areas outside the bank s assessment area(s) if the bank has adequately addressed the needs of its assessment area(s)
14 Ratings are subject to contextual data, business strategy, and available resources
15 Ratings Reflect the Dynamic Environment To Determine How Much is Enough, Consider: What s your size and what are your current constraints? Who s your competition and what are they doing? What are the needs and opportunities within the assessment area(s)? Ratings are described as follows:
16 Performance is considered Outstanding if the bank demonstrates: A high level of community development loans, community development services, or qualified investments Extensive use of innovative or complex qualified investments, community development loans, or community development services Excellent responsiveness to credit and community development needs in its assessment area(s)
17 Performance is considered Satisfactory if the bank demonstrates: An adequate level of community development loans, community development services, or qualified investments Occasional use of innovative or complex qualified investments, community development loans, or community development services Adequate responsiveness to credit and community development needs in its assessment area(s)
18 Performance is considered Needs to Improve if the bank demonstrates: A poor level of community development loans, community development services, or qualified investments Rare use of innovative or complex qualified investments, community development loans, or community development services Poor responsiveness to credit and community development needs in its assessment area(s)
19 Performance is considered Substantial Noncompliance if the bank demonstrates: Few, if any,, community development loans, community development services, or qualified investments No use of innovative or complex qualified investments, community development loans, or community development services Very yp poor responsiveness to credit and community development needs in its assessment area(s)
20 The Q&As clarify that a designated institution does not need to engage in all three activities (lending, investment, and service) to perform well under the community development test
21 Work closely with your regulator during an exam to ensure that a complete and accurate story is told make sure your performance is adequately documented d
22 Remember that nothing is written in stone if you re unsure about an issue, start a dialogue with your regulator
23 QUESTIONS?
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