Large Institutions | Examination Scope

For institutions (interstate and intrastate) with more than one assessment area, identify assessment areas for a full-scope review. A full-scope review is accomplished when examiners complete all of the procedures for an assessment area. For interstate institutions, a minimum of one assessment area from each state, and a minimum of one assessment area from each multistate metropolitan statistical area/metropolitan division (MSA/MD), must be reviewed using the full-scope examination procedures.

1. Review prior Community Reinvestment Act (CRA) performance evaluations, available community contact materials, Home Mortgage Disclosure Act (HMDA) and CRA performance data including the institution’s lending, investment, and service activities by assessment area, the lending of other lenders in those markets, and demographic information from those markets.

2. Select assessment areas for full-scope review by considering the factors below.

a. The lending, investment, and service opportunities in the different assessment areas, particularly areas where the need for bank credit, investments and services is significant;

b. The level of the institution’s lending, investment, and service activity in the different assessment areas, including in 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 dispersion;2

c. The number of other institutions in the different assessment areas and the importance of the institution under examination in serving the different areas, particularly any areas with relatively few other providers of financial services;

d. Comments and feedback received from community groups and the public regarding the institution’s CRA performance;

e. The size of the population;

f. The existence of apparent anomalies in the reported CRA or HMDA data for any particular assessment area(s);  3

g. The length of time since the assessment area(s) was last examined using a full-scope review;

h. The institution’s prior CRA performance in different assessment areas;

i. Examiners’ knowledge of the same or similar assessment areas; and j. Issues raised in CRA performance evaluations of other institutions and prior community contacts in the institution’s assessment areas or similar assessment areas.

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

[2] A list of distressed or underserved nonmetropolitan middle-income geographies is available on the Federal Financial Institutions Examination Council (FFIEC) web site at www.ffiec.gov.

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

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