§__.24(d)(3) Alternative Systems for Delivering Retail Banking Services
§__.24(d)(3) – 1 Q: How do examiners evaluate alternative systems for delivering retail banking services? A1. There are a number of alternative systems used by financial institutions to deliver retail banking services to customers. Non-branch delivery systems, such as ATMs, online and mobile banking, and other means by which institutions provide services to their customers evolve over time. No matter the…
§__.24(d)(3) Debit Cards as Alternative Delivery System
§__.24(d)(3) – 2 Q: Are debit cards considered under the service test as an alternative delivery system? A2. By themselves, no. However, if debit cards are a part of a larger combination of products, such as a comprehensive electronic banking service, that allows an institution to deliver needed services to low- and moderate-income areas and individuals in its…
§__.24(d)(4) Evaluation of Services and Tailoring to Meet Community Needs
§__.24(d)(4) – 1 Q: How do examiners evaluate the range of services provided in low-, moderate-, middle-, and upper-income geographies and the degree to which those services are tailored to meet the needs of those geographies? A1. Examiners review both information from the institution’s public file and other information provided related to the range of services offered…
§__24(e) Community Development Services by Affiliates or Third Parties
§__.24(e) – 1 Q: Under what conditions may an institution receive consideration for community development services offered by affiliates or third parties? A1. At an institution’s option, the Agencies will consider services performed by an affiliate or by a third party on the institution’s behalf under the service test if the services provided enable the institution to…
§__.24(e) Quantitative and Qualitative Factors in Service Evaluation
§__.24(e) – 2 Q: In evaluating community development services, what quantitative and qualitative factors do examiners review? A2. The community development services criteria are important factors in the evaluation of a large institution’s service test performance. According to the regulation, the Agencies evaluate the extent to which the financial institution provides community development services as well as…
§__.25(a) Credit Card Bank Exemption
§__.25(a) – 1 Q: How can certain credit card banks help to meet the credit needs of their communities without losing their exemption from the definition of “bank” in the Bank Holding Company Act (BHCA), as amended by the Competitive Equality Banking Act of 1987 (CEBA)? A1. Although the BHCA restricts institutions known as CEBA credit card…
§__.25(d) Investments in Third-Party Community Development Organizations
§__.25(d) – 1 Q: How are investments in third-party community development organizations considered under the community development test? A1. Similar to the lending test for retail institutions, investments in third-party community development organizations may be considered as qualified investments or as community development loans or both (provided there is no double counting), at the institution’s option, as described…
§__.25(e) Wholesale or Limited Purpose Institution Investment in Nationwide Fund
§__.25(e) – 1 Q: How do examiners evaluate a wholesale or limited purpose institution’s qualified investment in a fund that invested in projects nationwide and which has a primary purpose of community development, as this is defined in the regulations? A1. If examiners find that a wholesale or limited purpose institution has adequately addressed the needs of its…
§__.25(f) Wholesale or Limited Purpose Institution Performance Rating
§__.25(f) – 1 Q: Must a wholesale or limited purpose institution engage in all three categories of community development activities (lending, investment, and service) to perform well under the community development test? A1. No, a wholesale or limited purpose institution may perform well under the community development test by engaging in one or more of these activities….
§__.26 Small Institution Performance Standards for Affiliate Activities
§__.26 – 1 Q: When evaluating a small or intermediate small institution’s performance, will examiners consider, at the institution’s request, retail and community development loans originated or purchased by affiliates, qualified investments made by affiliates, or community development services provided by affiliates? A1. Yes. However, a small institution that elects to have examiners consider affiliate activities must…