Small Institutions | Examination Scope

Examination Scope

1 – For institutions with more than one assessment area, identify assessment areas for full scope review. In making those selections, review prior CRA performance evaluations, available community contact materials, and reported lending data and demographic data on each assessment area. Consider factors such as:

a- The lending opportunities in the different assessment areas;

b- The level of the institution’s lending 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 Agencies[1] 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 – The existence of apparent anomalies in the reported HMDA data for any particular assessment area(s);

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

f- The institution’s prior CRA performance in different assessment areas;

g- Examiners’ knowledge of the same or similar assessment areas; and

f – 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 for each multi-state MSA or metropolitan division (MD) where the institution has branches in two or more states that comprise that multi-state MSA/MD. Select one or more assessment areas in each state for examination using these procedures.

[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:  Small Institution CRA Examination Procedures | OCC, FRB, FDIC and OTS | July 2007

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