Wholesale or Limited Purpose 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. Consider, among other things, whether housing costs are particularly high in relation to area median income.

2. Consider any information the institution may provide on its local community and economy and its community development lending, qualified investment, and community development service capacity or that otherwise assists in the evaluation of the institution’s community development activities.

3. Review community contact forms prepared by the regulatory agencies to obtain information that assists in the evaluation of the institution’s community development activities. Contact local community, government, or economic development representatives to update or supplement information about community development activities in the assessment area(s) or the broader statewide or regional areas of which the assessment area(s) is a part.

4. Identify barriers, if any, to participation by the institution in local community development activities. For example, evaluate the institution’s ability and capacity to help meet the community development needs of its assessment area(s) through a review of the Uniform Bank Performance Report (UBPR) / Uniform Thrift Performance Report (UTPR), the Consolidated Report of Condition (Call Report) / Thrift Financial Report (TFR), annual reports, supervisory reports, prior CRA performance evaluations, and financial information for other wholesale/limited purpose institutions serving approximately the same assessment area(s).

5. Review the institution’s public file and any comments received by the institution or the agency since the last CRA performance evaluation for information that assists in the evaluation of the institution.

6. Document the performance context information gathered for use in evaluating the institution’s CRA record.


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