Large Institutions | Ratings

1. Group the analyses of the assessment areas examined by MSA3 and nonmetropolitan areas within each state where the institution has branches. If an institution has branches in two or more states of a multistate MSA, group the assessment areas that are in that multistate MSA.

2. Summarize conclusions regarding the institution’s performance in each MSA and nonmetropolitan portion of each state with an assessment area that was examined using these procedures. If two or more assessment areas in an MSA or in a nonmetropolitan portion of a state were examined using these procedures, determine the relative significance of the institution’s performance in each assessment area by considering:

a. The significance of the institution’s lending, qualified investments, and lending-related services in each compared to:

i. The institution’s overall activities;

ii. The number of other institutions and the extent of their activities; and

iii. The lending, investment, and service opportunities in each. b. Demographic and economic conditions in each.

3. Evaluate the institution’s performance in those assessment area(s) not selected for examination using the full-scope procedures.

a. Revisit the demographic and lending, investment, and service data considered in scoping the examination. Also, consider the institution’s operations (branches, lending portfolio mix, etc.) in the assessment area(s).

b. Through a review of the public file(s), consider any services that are customized to the assessment area(s).

c. Consider any other information provided by the institution (e.g., CRA self-assessment) regarding its performance in the area.

4. For MSAs, and the nonmetropolitan portion of the state, where one or more assessment areas were examined using the full-scope procedures, ensure that performance in the assessment area(s) not examined using the full-scope procedures is consistent with the conclusions based on the assessment area(s) examined in step 2, above. Select one of the following options for inclusion in the performance evaluation:

a. The institution’s [lending, investment, service] performance in [the assessment area/these assessment areas] is consistent with the institution’s [lending, investment, service] performance in the assessment areas within [the MSA/nonmetropolitan portion of the state] that were reviewed using the examination procedures.

b. The institution’s [lending/investment/service] performance in [the assessment area/these assessment areas] [exceeds/is below] the [lending/investment/service] performance in the assessment areas within [the MSA/nonmetropolitan portion of the state] that were reviewed using the examination procedures; however, it does not change the conclusion for the [MSA/nonmetropolitan portion of the state].

5. For MSA, and nonmetropolitan portions of the state, where no assessment area was examined using the full-scope procedures, form a conclusion regarding the institution’s lending, investment, and service performance in the assessment area(s). When there are several assessment areas in the MSA, or the nonmetropolitan portion of the state, form a conclusion regarding the institution’s performance in the MSA, or the nonmetropolitan portion of the state. Determine the relative significance of the institution’s performance in each assessment area within the MSA, or the nonmetropolitan portion of the state, by considering:

a. The significance of the institution’s lending, qualified investments, and lending-related services in each compared to the institution’s overall activities.

b. Demographic and economic conditions in each.

6. Also, select one of the following options for inclusion in the performance evaluation:

a. The institution’s [lending, investment, service] performance in [the assessment area/these assessment areas] is consistent with the institution’s [lending, investment, service] performance [overall/in the state].

b. The institution’s [lending/investment/service] performance in [the assessment area/these assessment areas] [exceeds/is below] the [lending/investment/service] performance for the [institution/state], however, it does not change the [institution’s/state] rating.

7. Determine the relative significance of each MSA and nonmetropolitan area to the institution’s overall performance (institutions operating in one state) or statewide or multistate MSA performance (institutions operating in more than one state). Consider:

a. The significance of the institution’s lending, qualified investments, and lending-related services in each compared to:

i. The institution’s overall activities;

ii. The number of other institutions and the extent of their activities; and

iii. The lending, investment, and service opportunities in each. b. Demographic and economic conditions in each.

8. When determining the state or multistate MSA rating, as applicable, consider:

a. Community development loans and services and qualified investments in the institution’s assessment area(s) in the state or multistate MSA;

b. Community development loans and services and qualified investments:

i. In the broader statewide or regional area that includes the institution’s assessment area(s) in the state or multistate MSA; and

ii. That support organizations or activities with a purpose, mandate, or function that includes serving individuals or geographies in the institution’s assessment area(s); and

c. If the institution has been responsive to community development needs and opportunities in its assessment area(s) based on the analysis in steps 8a and 8b, consider any community development loans and services and qualified investments in the broader statewide or regional area that includes the institution’s assessment area(s) in the state or multistate MSA that:

i. Will not benefit the assessment area(s); and

ii. Do not support organizations or activities with a purpose, mandate, or function that includes serving geographies or individuals located within the institution’s assessment area(s).

9. Using the Component Test Ratings chart, below, assign component ratings that reflect the institution’s lending, investment, and service performance. In the case of an institution with branches in just one state, one set of component ratings will be assigned to the institution. In the case of an institution with branches in two or more states and multistate MSAs, component ratings will be assigned for each state or multistate MSA reviewed.

COMPONENT TEST RATINGS Points for Lending Points for Investment Points for Service
Outstanding 12 Points 6 Points 6 Points
High Satisfactory 9 Points 4 Points 4 Points
Low Satisfactory 6 Points 3 Points 3 Points
Needs To Improve 3 Points 1 Point 1 Point
Substantial Noncompliance 0 Points 0 Points 0 Points

10. Assign a preliminary composite rating for the institutions operating in only one state and a preliminary rating for each state or multistate MSA reviewed for institutions operating in more than one state. In assigning the rating, sum the numerical values of the component test ratings for the lending, investment and service tests and refer to the chart, below. No institution, however, may receive an assigned rating of “Satisfactory” or higher unless it receives a rating of at least “Low Satisfactory” on the lending test. In addition, an institution’s assigned rating can be no more than three times the score on the lending test.

Composite Rating Points Needed
Outstanding 20 Points or over
Satisfactory 11 through 19 Points
Needs To Improve 5 through 10 Points
Substantial Noncompliance 0 through 4 Points

11. Consider an institution’s past performance if the prior rating was “Needs to Improve.” If the poor performance has continued, an institution could be considered for a “Substantial Noncompliance” rating.

12. For institutions with branches in more than one state or multistate MSA, assign a preliminary overall rating.

a. To determine the relative importance of each state and multistate MSA to the institution’s overall rating, consider:

i. The significance of the institution’s lending, qualified investments, and lendingrelated services in each compared to:

1. The institution’s overall activities;

2. The number of other institutions and the extent of their activities in each; and

3. The lending, investment, and service opportunities in each.

ii. Demographic and economic conditions in each.

b. Consider the community development loans and services and qualified investments that meet the geographic requirements and that have not been considered in assigning state or multistate MSA ratings. For example, a qualified investment in a regional or nationwide fund that meets the geographic requirements and benefits more than one state, but was not considered because the benefits are not attributable to a particular state or multistate MSA, would be considered at the overall institution level.

13. Review the results of the most recent compliance examination and determine whether evidence of discriminatory or other illegal credit practices that violate an applicable law, rule, or regulation should lower the institution’s preliminary overall CRA rating, or the preliminary CRA rating for a state or multistate MSA.4 If evidence of discrimination or other illegal credit practices by the institution in any geography, or in any assessment area by any affiliate whose loans have been considered as part of the bank’s lending performance, was found, consider the following:

a. The nature, extent, and strength of the evidence of the practices;

b. The policies and procedures that the institution (or affiliate, as applicable) has in place to prevent the practices;

c. Any corrective action the institution (or affiliate, as applicable) has taken, or has committed to take, including voluntary corrective action resulting from self-assessment; and

d. Any other relevant information.

14. Assign final overall rating to the institution. Consider:

a. The preliminary rating; and

15. Any evidence of discriminatory or other illegal credit practices, and discuss conclusions with management.

16. Write comments and conclusions, and create charts and tables reflecting area demographics, the institution’s operation and its lending, investment and service activity in each assessment area for inclusion in the performance evaluation.

17. Prepare recommendations for supervisory strategy and matters that require attention for follow-up activities.

_____________________

3 The reference to MSA may also reference MD.

4 “Evidence of discriminatory or other illegal credit practices” includes, but is not limited to: (a) Discrimination against applicants on a prohibited basis in violation, for example, of the Equal Credit Opportunity Act or the Fair Housing Act; (b) Violations of the Home Ownership and Equity Protection Act; (c) Violations of section 5 of the Federal Trade Commission Act; (d) Violations of section 8 of the Real Estate Settlement Procedures Act; and (e) Violations of the Truth in Lending Act regarding a consumer’s right of rescission.

 

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

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