CRA - ISB Part 2 PDF

XI. Community Reinvestment Act — Intermediate Small Bank d. Information about demographic or other characteristics of particular geographies that could affect loan demand, such as the existence of a prison or college; and e. Information about other lenders serving the same or similar assessment are...

XI. Community Reinvestment Act — Intermediate Small Bank d. Information about demographic or other characteristics of particular geographies that could affect loan demand, such as the existence of a prison or college; and e. Information about other lenders serving the same or similar assessment area(s). 8. Summarize in work papers conclusions concerning the geographic distribution of loans and the distribution of loans by borrower characteristics in the institution’s assessment area(s). XI–3.4 Review of Complaints 1. Review all complaints relating to the institution’s CRA performance received by the institution (these should all be contained in the institution’s public file) and those that were received by its supervisory agency. 2. If there were any complaints, evaluate the institution’s record of taking action, if warranted, in response to written complaints about its CRA performance. 3. If there were any complaints, discuss the preliminary findings in this section with management. 4. If there were any complaints, summarize in work papers conclusions regarding the institution’s record of taking action, if warranted, in response to written complaints about its CRA performance. Include the total number of complaints and resolutions with examples that illustrate the nature, responsiveness to, and resolution of, the complaints. 5. Discuss the preliminary findings in the lending test section with management. FDIC Consumer Compliance Examination Manual — September 2015 XI. Community Reinvestment Act — Intermediate Small Bank CRA Ratings Matrix — Intermediate Small Institutions Characteristic Outstanding Satisfactory Needs to Improve Substantial Noncompliance Loan-to-Deposit Ratio The loan-to-deposit ratio is more than reasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. The loan-to-deposit ratio is reasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. The loan-to-deposit ratio is less than reasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. The loan-to-deposit ratio is unreasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. Assessment Area(s) Concentration A substantial majority of loans and other lending related activities are in the institution’s assessment area(s). A majority of loans and other lending related activities are in the institution’s assessment area(s). A majority of loans and other lending related activities are outside the institution’s assessment area(s) A substantial majority of loans and other lending related activities are outside the institution’s assessment area(s) Geographic Distribution of Loans The geographic distribution of loans reflects excellent dispersion throughout the assessment area(s). The geographic distribution of loans reflects reasonable dispersion throughout the assessment area(s). The geographic distribution of loans reflects poor dispersion throughout the assessment area(s). The geographic distribution of loans reflects very poor dispersion throughout the assessment area(s). Borrower’s Profile The distribution of borrowers reflects, given the demographics of the assessment area(s), excellent penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. The distribution of borrowers reflects, given the demographics of the assessment area(s), reasonable penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. The distribution of borrowers reflects, given the demographics of the assessment area(s), poor penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. The distribution of borrowers reflects, given the demographics of the assessment area(s), very poor penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. Response to Substantiated Complaints The institution has taken noteworthy, creative action in response to substantiated complaints about its performance in meeting assessment area credit needs. The institution has taken appropriate action in response to substantiated complaints about its performance in meeting assessment area credit needs. The institution has taken inadequate action in response to substantiated complaints about its performance in meeting assessment area credit needs. The institution is unresponsive to substantiated complaints about its performance in meeting assessment area credit needs. FDIC Consumer Compliance Examination Manual — September 2015 XI–3.5 XI. Community Reinvestment Act — Intermediate Small Bank Intermediate Small Institution Community Development Test An institution should appropriately assess the needs in its community, engage in different types of community development activities based on those needs and the institution’s capacities, and take reasonable steps to apply its community development resources strategically to meet those needs. The flexibility inherent in the community development test allows intermediate small institutions to focus on meeting the substance of community needs through these activities. Examiners will consider the results of any assessment by the institution of community needs along with information from community, government, civic, and other sources to gain a working knowledge of community needs. 1. Identify the number and amount of the institution’s community development loans, qualified investments, and community development services. Obtain this information through discussions with management, HMDA data collected by the institution, as applicable; investment portfolios; any other relevant financial records; and materials available to the public. Include, at the institution’s option: a. Community development loans, qualified investments, and community development services provided by affiliates, if they are not claimed by any other institution; and b. Community development lending by consortia or third parties. 2. Review community development loans, qualified investments, and community development services to verify that they qualify as community development. 3. If the institution participates in community development lending by consortia or third parties, or claims activities provided by affiliates, review records provided to the institution by the consortia or third parties or affiliates to XI–3.6 ensure that the community development loans claimed by the institution do not account for more than the institution’s share (based on the level of its participation or investment) of the total loans originated by the consortium or third party. 4. Considering the institution’s capacity and constraints and other information obtained through the performance context review, form conclusions about: a. The number and amount of community development loans and qualified investments; b. The extent to which the institution provides community development services, including the provision and availability of services to low- and moderate-income people, including through branches and other facilities in low- and moderate-income areas; c. The responsiveness to the opportunities for community development lending, qualified investments, and community development services, considering: 1) The results of any assessment of community development needs and opportunities provided by the institution; 2) The examiner’s review of performance context information from community, government, civic, and other sources; and 3) Whether the amount and combination of community development loans, qualified investments, and community development services, along with their qualitative aspects, are responsive to community needs and opportunities. 5. Summarize conclusions regarding the institution’s community development performance and retain in the work papers. FDIC Consumer Compliance Examination Manual — September 2015