Intermediate Small Institutions | Performance Context

1 – Review standardized worksheets and other agency information sources to obtain relevant demographic, economic, and loan data, to the extent available, for each assessment area under review.

2 – Obtain for review the Consolidated Reports of Condition (Call Reports) / Thrift Financial Reports (TFR), Uniform Bank Performance Reports (UBPR) / Uniform Thrift Performance Reports (UTPR), annual reports, supervisory reports, and prior CRA evaluations of the institution under examination to help understand the institution’s ability and capacity, including any limitations imposed by size, financial condition, or statutory, regulatory, economic or other constraints, to respond to see and sound opportunities in the assessment area(s) for retail loans, and community development loans, investments and services.

3 – Discuss with the institutions, and consider, any information the institution may provide about its local community and economy, including community development needs and opportunities, its business strategy, its lending capacity, or information that otherwise assists in the evaluation of the institution.

4 – Review community contact forms prepared by the regulatory agencies to obtain information that assists in the evaluation of the institution. Contact local community, governmental or economic development representatives to update or supplement this information. Refers to the Community Contact Procedures for more detail.

5 – Review any comments received by the institution or the agency since the last CRA examination.

6 – By reviewing the public evaluations and other financial data, determine whether any similarly situated institutions (in terms of size, financial condition, product offerings, and business strategy) serve the same or similar assessment area(s) and would provide relevant and accurate information for evaluating the institution’s CRA performance. Consider, for example, whether the information could help identify:

a – Lending and community development opportunities available in the institution’s assessment area(s) that are compatible with the institution’s business strategy and consistent with safe and sound banking practices;

b – Constraints affecting the opportunities to make safe and sound retail loans, community development loans, qualified investments, and community development services compatible with the institution’s business strategy in the assessment area(s); and

c – Successful CRA-related product offerings or activities utilized by other lenders serving the same or similar assessment area(s).

7 – Document the performance context information, particularly community development needs and opportunities, gathered for use in evaluating the institution’s performance.


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