Wholesale or Limited Purpose Institutions | Community Development Test

1. Identify the number and amount of the institution’s community development loans, (originations and purchases of loans and any other data the institution chooses to provide), qualified investments, and community development services. Obtain this information through discussions with management, HMDA data collected by the institution, as applicable; investment portfolios; any other relevant financial records; and materials available to the public. Include, at the institution’s option:

a. Community development loans, qualified investments, and community development services provided by affiliates, if they are not claimed by any other institution; and

b. Community development lending by consortia or third parties.

2. Review community development loans, qualified investments, and community development services to verify that they qualify as community development.

3. If the institution participates in community development lending by consortia or third parties, or claims activities provided by affiliates, review records provided to the institution by the consortia or third parties or affiliates to ensure that the community development loans claimed by the institution do not account for more than the institution’s share (based on the level of its participation or investment) of the total loans originated by the consortium or third party.

4. Considering the institution’s capacity and constraints and other information obtained through the performance context review, form conclusions about:

a. The extent, by number and dollar amount of community development loans, services, and qualified investments;

b. The degree of innovation in community development activities (e.g., serving low- or moderate-income borrowers in new ways or serving groups of creditworthy borrowers not previously served by the institution);

c. The complexity of those community development activities, such as the use of enhancements or other features specifically designed to expand community development lending;

d. The responsiveness to the opportunities for community development lending, qualified investments, and community development services; and

e. The degree to which the institution’s qualified investments serve needs not routinely provided by other private investors.

5. Summarize conclusions regarding the institution’s community development performance and retain in the work papers.


SOURCE:  Wholesale/Limited Purpose CRA Examination Procedures | OCC, FRB, FDIC, and OTS | July 2007

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