Large Institutions | Appendix to CRA Examination Procedures

Community Development Loans and Services and Qualified Investments
  Qualified community development (CD) activities in the assessment area (AA) or the broader statewide or regional area that includes the AA(s)
  Has a purpose, mandate, or function that includes serving the AA Does not have a purpose, mandate, or function that includes serving the AA
Initial level activity is considered during the evaluation: Specific AA when an activity benefits and is targeted to the AA.

 

State/Multistate MSA when an activity benefits or is targeted to two or more AAs, or the state or multistate MSA.

 

Institution level when an activity benefits or is targeted to:

·       A regional area of two or more states not in a multistate MSA, or

·       A regional area that includes, but is larger than one multistate MSA.

If the institution has been responsive to CD needs and opportunities in its AA(s), these activities may enhance performance at the state, multistate MSA, or institution level as applicable.

 

State/Multistate MSA when the activity benefits geographies or individuals located in a state or multistate MSA where the bank has one or more defined AA.

 

Institution level when the activity is in the broader regional area that includes the bank’s AA(s).

Note: It is not appropriate to assign activities to a specific AA or state unless the bank can demonstrate the activity benefitted, and was targeted to, the AA or state.
PE comments: Specific AA – Discuss conclusions regarding evaluation of the level of activity. Comment on the quantitative measure of the loan/investment/service and the qualitative aspects that augmented performance levels.

 

State/Multistate MSA – Discuss conclusions regarding evaluation of the level of activity. Comment on the quantitative measure of all loans, investments, and services in all the AA(s) in the state or multistate MSA combined. Include statewide and regional activities that contribute to the state/multistate MSA’s overall assessment and indicate if related amounts are in addition to or included in specific AA discussions or tables. Explain if loans, investments, and/or services for any AA were given greater weight than others and why. Comment generally on qualitative aspects that augmented performance, such as responsiveness to need, degree of innovation, or complexity.

 

Institution level – Discuss conclusions regarding evaluation of the level of activity. Comment on the quantitative measure of all loans, investments, and services in all states and multistate MSAs combined. Include regional and nationwide activities that contribute to the institution’s overall assessment and indicate if related amounts are in addition to or included in the specific state or multistate MSA discussions or tables. Explain if loans, investments, and/or services for any state or multistate MSA were given greater weight than others and why.   Comment generally on qualitative aspects that augmented performance, such as responsiveness to need, degree of innovation, or complexity.

Show in tables (when used): Specific AA – Include qualified activities the bank can demonstrate directly benefit or target the AA.

 

State/Multistate MSA – Separate line for qualified activities that support an organization or activity that covers an area that is larger than, but includes the institution’s AA, and has not been attributed to a specific AA. Include regional activities and nationwide investments that benefit, or are targeted, to a specific state or multistate MSA.

 

Institution level – Separate lines for 1) regional and 2) nationwide activities that were not otherwise attributed to a specific AA, state, or multistate MSA.

 

SOURCE:  Large Institution CRA Examination Procedures | OCC, FRB, and FDIC | April 2014

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