Institutions with Strategic Plans | Examination Scope

1. For institutions with more than one assessment area, identify assessment areas for full scope review. To select one or more assessment areas for full scope review, analyze prior performance evaluations, available community contact materials, reported lending data and demographic data on each assessment area and consider factors such as:

a. the level of the institution’s lending, investment, and service activity in the different assessment areas, including low- and moderate-income areas, designated disaster areas, or distressed or underserved nonmetropolitan middle-income geographies designated by the Agencies1 based on (a) rates of poverty, unemployment, and population loss or (b) population size, density, and dispersion2

b. The number of other institutions in the different assessment areas and the importance of the institution under examination in meeting credit needs in the different assessment areas, particularly in areas with a limited number of financial service providers;

c. The existence of apparent anomalies in the reported lending data for any particular assessment area(s);

d. The time since the assessment area(s) most recently received a full scope examination;

e. Performance that falls short of plan goals based on a review of available data;

f. The institution’s prior CRA performance in the different assessment areas; and

g. Comments from the public regarding the institution’s CRA performance.

2. For interstate institutions, a rating must be assigned for each state where the institution has a branch and in every multistate MSA where the institution has branches in two or more of the states that comprise that multistate MSA. Select one or more assessment areas in each state for examination using these procedures.

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1 The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision.

2 A list of distressed or underserved nonmetropolitan middle-income geographies is available on the FFIEC web site at www.ffiec.gov.

SOURCE:  Strategic Plan CRA Examination Procedures | OCC, FRB, FDIC, and OTS | July 2007

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