1. Review the following:
a. The approved plan and approved amendments;
b. The agency’s approval process files; and c. Written comments from the public that the institution or the agency received since the plan became effective.
2. Determine whether the institution achieved its performance goals for each assessment area examined.
a. Review the plan’s measurable annual goals for each performance category and assessment area(s) to be reviewed.
b. Obtain information and data about the institution’s actual performance for the period that has elapsed since the previous examination.
c. Compare the plan goals for each assessment area reviewed to the institution’s actual performance since its last examination in each assessment area reviewed to determine if all of the plan’s goals have been met.
3. If any goals were not met, form a conclusion as to whether the plan goals were “substantially met.” In doing so, consider the number of unmet goals, the degree to which the goals were not met, the importance of those goals to the plan as a whole, and the reasons why the goals were not met (e.g., economic factors beyond the institution’s control).
4. Discuss preliminary findings with management.
5. Summarize conclusions about the institution’s performance.
SOURCE: Strategic Plan CRA Examination Procedures | OCC, FRB, FDIC, and OTS | July 2007