Wholesale or Limited Purpose Institutions | Examination Scope

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

a. The lending, investment, and service activity in the different assessment areas, particularly community development activities;

b. The lending, investment, and service opportunities available in the different assessment areas, particularly community development opportunities;

c. The length of time since the assessment area(s) received a full scope review;

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

e. The number of other institutions in the assessment areas and the importance of the institution under examination in addressing community development needs in the different assessment areas, particularly in areas with a limited number of financial service providers;

f. The existence of apparent anomalies in the reported HMDA data for any particular assessment area;

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

h. 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 metropolitan statistical areas/metropolitan divisions (MSA/MD) where the institution has branches in two or more of the states that comprise the multi-state MSA/MD. Select one or more assessment areas in each state for examination using the full scope procedures


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

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