§__.26(b) Small Institution Lending-Related Activities

§__.26(b) – 1

Q: May examiners consider, under one or more of the performance criteria of the small institution performance standards, lending-related activities, such as community development loans and lending-related qualified investments, when evaluating a small institution?

A1. Yes. Examiners can consider “lending-related activities,” including community development loans and lending-related qualified investments, when evaluating the first four performance criteria of the small institution performance test. Although lending-related activities are specifically mentioned in the regulation in connection with only the first three criteria (i.e., loan-to-deposit ratio, percentage of loans in the institution’s assessment area(s), and lending to borrowers of different incomes and businesses of different sizes), examiners can also consider these activities when they evaluate the fourth criteria – geographic distribution of the institution’s loans.

Although lending-related community development activities are evaluated under the community development test applicable to intermediate small institutions, these activities may also augment the loan-to-deposit ratio analysis (12 CFR__.26(b)(1)) and the percentage of loans in the intermediate small institution’s assessment area(s) analysis (12 CFR__.26(b)(2)), if appropriate.

 

Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016

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