Revised Interagency Large Institution CRA Examination Procedures and Consolidation of Interagency CRA Examination Procedures and Supporting Materials

CA 14-2: Revised Interagency Large Institution CRA Examination Procedures and Consolidation of Interagency CRA Examination Procedures and Supporting Materials

BOARD OF GOVERNORS
OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551

DIVISION OF CONSUMER
AND COMMUNITY AFFAIRS

CA 14-2
April 18, 2014

Revised June 2, 2026

On June 2, 2026: Reputation risk is no longer a component of federal examination programs. See, e.g., Federal Reserve press release, OCC bulletin, and FDIC Financial Institution Letter.

TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS

SUBJECT:

Revised Interagency Large Institution CRA Examination Procedures and Consolidation of Interagency CRA Examination Procedures and Supporting Materials

Applicability to Community Banking Organizations: This guidance applies to all state member banks, including those with $10 billion or less in consolidated assets.

The Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the “Agencies”) recently approved the attached interagency Large Institution Community Reinvestment Act (CRA) examination procedures. The revised examination procedures explain how community development activities that benefit a broader statewide or regional area that includes an institution’s assessment area(s) and investments in nationwide funds will be considered when evaluating an institution’s CRA performance, assigning ratings, and developing public performance evaluations. The revised interagency Large Institution CRA examination procedures supersede the interagency Large Institution CRA examination procedures transmitted with CA Letter 06-9.

The revised examination procedures reflect, and are consistent with, the recently updated “Interagency Questions and Answers Regarding Community Reinvestment” (the “Questions and Answers”), which provides guidance for use by agency personnel, financial institutions, and the public. The Agencies updated the Questions and Answers on November 15, 2013 to address several community development issues.1

Additionally, this CA letter republishes, without change, the interagency Small Institution CRA examination procedures, the interagency Intermediate Small Institution CRA examination procedures, the interagency Wholesale/Limited Purpose CRA examination procedures, the interagency Strategic Plan CRA examination procedures, the Instructions for Writing Public Evaluations, and the FFIEC Community Contact Form, which were all previously transmitted with CA Letter 06-9.

signed by
Tonda Price
Acting Director
Division of Consumer and Community Affairs

Supersedes:

CA 06-9 “Consolidation of Interagency CRA Examination Procedures” (April 10, 2006)

Attachments:

Revised Interagency Large Institution CRA Examination Procedures Interagency Small Institution CRA Examination Procedures Interagency Intermediate Small Institution CRA Examination Procedures Interagency Wholesale/Limited Purpose CRA Examination Procedures Interagency Strategic Plan CRA Examination Procedures Instructions for Writing Public Evaluations FFIEC Community Contact Form

Cross References:

CA 13-18 “Final Revisions to Interagency Questions and Answers Regarding Community Reinvestment” (November 15, 2013)

Notes:

1. Refer to CA letter 13-18, "Final Revisions to Interagency Questions and Answers Regarding Community Reinvestment." Return to text

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TABLE OF CONTENTS
EXAMINATION PROCEDURES FOR LARGE INSTITUTIONS................................................................................. 2
EXAMINATION SCOPE..................................................................................................................................................... 2
PERFORMANCE CONTEXT............................................................................................................................................. 3
ASSESSMENT AREA .......................................................................................................................................................... 4
LENDING, INVESTMENT, AND SERVICE TESTS FOR LARGE RETAIL INSTITUTIONS................................. 5
LENDING TEST ..................................................................................................................................................................... 5
INVESTMENT TEST .............................................................................................................................................................10
SERVICE TEST ....................................................................................................................................................................12
RATINGS.............................................................................................................................................................................14
PUBLIC FILE CHECKLIST .............................................................................................................................................19
APPENDIX TO LARGE INSTITUTION CRA EXAMINATION PROCEDURES.....................................................21

COMMUNITY REINVESTMENT ACT
EXAMINATION PROCEDURES FOR LARGE INSTITUTIONS
Examination Scope
For institutions (interstate and intrastate) with more than one assessment area, identify assessment areas for a full-scope review. A full-scope review is accomplished when examiners complete all of the procedures for an assessment area. For interstate institutions, a minimum of one assessment area from each state, and a minimum of one assessment area from each multistate metropolitan statistical area/metropolitan division (MSA/MD), must be reviewed using the full-scope examination procedures.

1. Review prior Community Reinvestment Act (CRA) performance evaluations, available
   community contact materials, Home Mortgage Disclosure Act (HMDA) and CRA performance data including the institution's lending, investment, and service activities by assessment area, the lending of other lenders in those markets, and demographic information from those markets.
2. Select assessment areas for full-scope review by considering the factors below.
   a. The lending, investment, and service opportunities in the different assessment areas, particularly areas where the need for bank credit, investments and services is significant; b. The level of the institution's lending, investment, and service activity in the different assessment areas, including in low- and moderate-income areas, designated disaster areas, or distressed or underserved nonmetropolitan middle-income geographies designated by the Agencies1 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. Comments and feedback received from community groups and the public regarding the institution's CRA performance; e. The size of the population; f. The existence of apparent anomalies in the reported CRA or HMDA data for any particular assessment area(s); 1 The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency. A list of distressed or underserved nonmetropolitan middle-income geographies is available on the Federal Financial Institutions Examination Council (FFIEC) web site at www.ffiec.gov.

g. The length of time since the assessment area(s) was last examined using a full-scope review; h. The institution's prior CRA performance in different assessment areas;
i. Examiners’ knowledge of the same or similar assessment areas; and
j. Issues raised in CRA performance evaluations of other institutions and prior community contacts in the institution's assessment areas or similar assessment areas. 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. Compare the data to similar data for the MSA/MD, county, or state to determine how any similarities or differences will help in evaluating lending, investment, and service opportunities and community and economic conditions in the assessment area. Also consider whether the area has housing costs that are particularly high given area median income.
2. Obtain for review the Consolidated Reports of Condition (Call Reports), Uniform Bank
   Performance Reports (UBPR), annual reports, supervisory reports, and prior CRA evaluations of the institution 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 safe and sound opportunities in the assessment area(s) for retail loans, and community development loans, investments and services.
3. Discuss with the institution, 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. Refer to the Community Contact Procedures for more detail.
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. By reviewing performance 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. Assessment Area

1. Review the institution's stated assessment area(s) to ensure that it:
   a. Consists of one or more MSAs/MDs or contiguous political subdivisions (i.e., counties, cities, or towns); b. Includes the geographies where the institution has its main office, branches, and deposit￾taking (Automated Teller Machines) ATMs, as well as the surrounding geographies in which the institution originated or purchased a substantial portion of its loans;
   c. Consists only of whole census tracts;
   d. Consists of separate delineations for areas that extend substantially across MSA/MD or state boundaries unless the assessment area is in a multistate MSA/MD; e. Does not reflect illegal discrimination; and f. Does not arbitrarily exclude any low- or moderate-income area(s) taking into account the institution's size, branching structure, and financial condition.
2. If the assessment area(s) does not coincide with the boundaries of an MSA/MD or political
   subdivision(s), assess whether the adjustments to the boundaries were made because the assessment area would otherwise be too large for the institution to reasonably serve, have an unusual configuration, or include significant geographic barriers.
3. If the assessment area(s) fails to comply with the applicable criteria described above, develop,
   based on discussions with management, a revised assessment area(s) that complies with the

criteria. Use this assessment area(s) to evaluate the institution's performance, but do not otherwise consider the revision in determining the institution's rating. Lending, Investment, and Service Tests for Large Retail Institutions Lending Test

1. Identify the institution's loans to be evaluated by reviewing:
   a. The most recent HMDA and CRA Disclosure Statements, the interim HMDA Loan Application Register (LAR), and any interim CRA loan data collected by the institution; b. A sample of consumer loans if consumer lending represents a substantial majority of the institution's business so that an accurate conclusion concerning the institution's lending record could not be reached without a review of consumer loans;
   c. Any other information the institution chooses to provide, such as small business loans
   secured by non-farm residential real estate, home equity loans not reported for HMDA, unfunded commitments, any information on loans outstanding, and loan distribution analyses conducted by or for the institution, including any explanations for identified concerns or actions taken to address them.
2. Test a sample of loan files to verify the accuracy of data collected and/or reported by the
   institution. In addition, ensure that:
   a. Affiliate loans reported by the institution are not also attributed to the lending record of another affiliate subject to CRA. This can be accomplished by requesting the institution to identify how loans are attributed and how it ensures that all the loans within a given lending category (e.g., small business loans, home purchase loans, motor vehicle, credit card, home equity, other secured, and other unsecured loans) in a particular assessment area are reported for all of the institution's affiliates if the institution elects to count any affiliate loans; b. Loans reported as community development loans (including those originated or purchased by consortia or third parties) meet the definition of community development loans. Determine whether community development loans benefit the institution's assessment area(s) or a broader statewide or regional area that includes the institution's assessment area(s). Except for multifamily loans, ensure that community development loans have not also been reported by the institution or an affiliate as HMDA, small business or farm, or consumer loans. Review records provided to the institution by consortia or third parties or affiliates to ensure that the amount of the institution's third party or consortia or affiliate lending does not account for more than the institution's percentage share (based on the level of its participation or investment) of the total loans originated by the consortia, third parties, or affiliates;

c. All consumer loans in a particular loan category have been included when the institution
collects and maintains the data for one or more loan categories and has elected to have the information evaluated.
3. Identify the volume, both in number and dollar amount, of each type of loan being evaluated
that the institution has made or purchased within its assessment area. Evaluate the institution's lending volume considering the institution's resources and business strategy and other information from the performance context, such as population, income, housing, and business data. Note whether the institution conducts certain lending activities in the institution and other activities in an affiliate in a way that could inappropriately influence an evaluation of borrower or geographic distribution.
4. Review any analyses prepared by or for and offered by the institution for insight into the
reasonableness of the institution's geographic distribution of lending. Test the accuracy of the data and determine if the analyses are reasonable. If areas of low or no penetration were identified, review explanations and determine whether action was taken to address disparities, if appropriate.
5. Supplement with an independent analysis of geographic distribution as necessary. As
applicable, determine the extent to which the institution is serving geographies in each income category and whether there are conspicuous gaps unexplained by the performance context. Conclusions should recognize that institutions are not required to lend in every geography. The analysis should consider:
a. (Excluding affiliate lending) the number, dollar amount, and percentage of the institution's loans located within any of its assessment areas, as well as the number, dollar amount, and percentage of the institution's loans located outside any of its assessment areas; b. The number, dollar amount, and percentage of each type of loan in the institution's portfolio in each geography, and in each category of geography (low-, moderate-, middle-, and upper-income);
c. The number of geographies penetrated in each income category, as determined in step (b),
and the total number of geographies in each income category within the assessment area(s); d. The number and dollar amount of its home purchase, home refinancing, and home improvement loans, respectively in each geography compared to the number of one-to-four family owner-occupied units in each geography; e. The number and dollar amount of multifamily loans in each geography compared to the number of multifamily structures in each geography; f. The number and dollar amount of small business and farm loans in each geography compared to the number of small businesses/farms in each geography;

g. Whether any gaps exist in lending activity for each income category, by identifying groups of contiguous geographies that have no loans or those with low penetration relative to the other geographies.
6. If there are groups of contiguous geographies within the institution's assessment area with
abnormally low penetration, the examiner may determine if an analysis of the institution's performance compared to other lenders for home mortgage loans (using reported HMDA data) and for small businesses and small farm loans (using data provided by lenders subject to CRA) would provide an insight into the institution's lack of performance in those areas. This analysis is not required, but may provide insight if:
a. The reported loan category is substantially related to the institution's business strategies; b. The area under analysis substantially overlaps the institution's assessment area(s);
c. The analysis includes a sufficient number and volume of transactions, and an adequate
number of lenders with assessment area(s) substantially overlapping the institution's assessment area(s); d. The assessment area data is free from anomalies that can cause distortions such as dominant lenders that are not subject to the CRA, a lender that dominates a part of an area used in calculating the overall lending, or there is an extraordinarily high level of performance, in the aggregate, by lenders in the institution's assessment area(s).
7. Using the analysis from step number 6, form a conclusion as to whether the institution's
abnormally low penetration in certain areas should constitute a negative consideration under the geographic distribution performance criteria of the lending test by considering:
a. The institution's share of reported loans made in low- and moderate-income geographies versus its share of reported loans made in middle- and upper-income geographies within the assessment area(s); b. The number of lenders with assessment area(s) substantially overlapping the institution's assessment area(s);
c. The reasons for penetration of these areas by other lenders, if any, and the lack of
penetration by the institution being examined that are developed through discussions with management and the community contact process; d. The institution's ability to serve the subject area in light of (i) the demographic characteristics, economic condition, credit opportunities and demand; and (ii) the institution's business strategy and its capacity and constraints; e. The degree to which penetration by the institution in the subject area in a different reported loan category compensates for the relative lack of penetration in the subject area; and

f. The degree to which penetration by the institution in other low- and moderate-income geographies within the assessment area(s) in reported loan categories compensates for the relative lack of penetration in the subject area.
8. Review any analyses prepared by or for and offered by the institution for insight into the
reasonableness of the institution's distribution of lending by borrower characteristics. Test the accuracy of the data and determine if the analyses are reasonable. If areas of low or no penetration were identified, review explanations and determine whether action was taken to address disparities, if appropriate.
9. Supplement with an independent analysis of the distribution of the institution's lending within
the assessment area by borrower characteristics as necessary and applicable. Consider factors such as:
a. The number, dollar amount, and percentage of the institution's total home mortgage loans and consumer loans, if included in the evaluation, to low-, moderate-, middle-, and upper￾income borrowers; b. The percentage of the institution's total home mortgage loans and consumer loans, if included in the evaluation, to low-, moderate-, middle-, and upper-income borrowers compared to the percentage of the population within the assessment area who are low-, moderate-, middle-, and upper-income;
c. The number and dollar amount of small loans originated to businesses or farms by loan
size of less than $100,000; at least $100,000 but less than $250,000; and at least $250,000 but less than or equal to $1,000,000; d. The number and amount of the small loans to businesses or farms that had annual revenues of less than $1 million compared to the total reported number and amount of small loans to businesses or farms; and e. If the institution adequately serves borrowers within the assessment area(s), whether the distribution of the institution's lending outside of the assessment area based on borrower characteristics would enhance the assessment of the institution's overall performance.
10. Review data on the institution's community development loans using information obtained in
the performance context procedures, especially with regard to community credit needs and institutional capacity, to determine:
a. The number and amount of community development loans in:
i. The institution’s assessment area(s); or
ii. The broader statewide or regional area that includes the assessment area(s) that
support organizations or activities with a purpose, mandate, or function that includes

serving the geographies or individuals located within the institution’s assessment area(s). b. The extent to which community development lending opportunities have been available to the institution;
c. The institution’s responsiveness to the opportunities for community development lending;
d. The extent of leadership the institution has demonstrated in community development lending; and e. The innovativeness or complexity involved.
11. If the institution has been responsive to community development needs and opportunities in its
assessment area(s) based on the analysis in step number 10, consider:
a. The number and dollar amount of community development loans in the broader statewide or regional area that includes the assessment area(s), but:
i. Will not benefit the assessment area(s); and
ii. Do not support organizations or activities with a purpose, mandate, or function that
includes serving geographies or individuals located within the institution’s assessment area(s). b. The extent to which these loans enhance the institution’s performance. Note: Refer to the appendix for additional guidance on addressing activities at the state or multistate MSA, or institution level.
12. Evaluate whether the institution's performance under the lending test is enhanced by offering
innovative loan products or products with more flexible terms to meet the credit needs of low￾and moderate-income individuals or geographies. Consider:
a. The degree to which the loans serve low- and moderate-income creditworthy borrowers in new ways or loans serve groups of creditworthy borrowers not previously served by the institution; and b. The success of each product, including number and dollar amount of loans originated during the review period.
13. Discuss with management the preliminary findings in this section.
14. Summarize your conclusions regarding the institution's lending performance under the
following criteria:

a. Lending activity. b. Geographic distribution.
c. Borrower characteristics.
d. Community development lending. e. Use of innovative or flexible lending practices.
15. Prepare comments for the performance evaluation and the Compliance examination report.
Refer to the appendix for guidance on addressing community development activities in the performance evaluation. Investment Test

1. Identify qualified investments by reviewing the institution's investment portfolio, and at the
   institution's option, its affiliate's investment portfolio. As necessary, obtain a prospectus, or other information that describes the investment(s) and the geographic area(s) or population(s) served. This review should encompass qualified investments, including investments in a broader statewide or regional area and in nationwide funds, that were made since the previous examination (including those that have been sold or have matured) and may consider qualified investments made prior to the previous examination still outstanding. Also, consider qualifying grants, donations, or in-kind contributions of property since the last examination that are for community development purposes. Determine:
   a. Whether the investments have been considered under the lending or service tests; and b. Whether an affiliate's investments, if considered, have been claimed by another institution.
2. Evaluate investment performance using information obtained in the performance context
   procedures, especially with regard to community needs and institutional capacity. Determine:
   a. The number and amount of qualified investments in:
   i. The institution’s assessment area(s); or
   ii. The broader statewide or regional area that includes the assessment area(s) that
   support organizations or activities with a purpose, mandate, or function that includes serving the geographies or individuals located within the institution’s assessment area(s). Note: A large institution with a nationwide branch footprint typically has many assessment areas in many states. Investments in nationwide funds are likely to benefit such an institution’s assessment area(s), or the broader statewide or regional area that

includes its assessment area(s), and provide that institution with the opportunity to match its investments with the geographic scope of its business. b. The extent to which qualified investment opportunities have been available to the institution;
c. The institution’s responsiveness to opportunities for qualified investments;
d. The use of any innovative or complex investments, in particular those that are not routinely provided by other investors; and e. The degree to which investments serve low- and moderate-income areas or individuals, designated disaster areas, or distressed or underserved nonmetropolitan middle-income geographies, and the available opportunities for qualified investments.
3. If the institution has been responsive to community development needs and opportunities in its
assessment area(s) based on the analysis in step number 2, consider:
a. The number and dollar amount of qualified investments in the broader statewide or regional area that includes the assessment area(s), but:
i. Will not benefit the assessment area(s); and
ii. Do not support organizations or activities with a purpose, mandate, or function that
includes serving geographies or individuals located within the institution’s assessment area(s). b. The extent to which these investments enhance the institution’s performance. Note: Refer to the appendix for additional guidance on addressing activities at the state or multistate MSA, or institution level.
4. Discuss with management the preliminary findings in this section.
5. Summarize conclusions about the institution's investment performance after considering:
a. The number and dollar amount of qualified investments; b. The innovativeness and complexity of qualified investments;
c. The degree to which these qualified investments are not routinely provided by other private
investors; and d. The responsiveness of qualified investments to available opportunities.

6. Prepare comments for the performance evaluation and the Compliance examination report.
Refer to the appendix for guidance on addressing community development activities in the performance evaluation. Service Test Retail Banking Services
1. Determine from information available in the institution's public file:
a. The distribution of the institution's branches among low-, moderate-, middle-, and upper￾income geographies in the institution's assessment area(s); and b. Banking services, including hours of operation and available loan and deposit products.
2. Obtain the institution's explanation for any material differences in the hours of operations of,
or services available at, branches within low-, moderate-, middle-, and upper-income geographies in the institution's assessment area(s).
3. Evaluate the institution's record of opening and closing branch offices since the previous
examination and information that could indicate whether changes have had a positive or negative effect, particularly on low- and moderate-income geographies or individuals.
4. Evaluate the accessibility and use of alternative systems for delivering retail banking services,
(e.g., proprietary and non-proprietary ATMs, loan production offices (LPOs), banking by telephone or computer, and bank-at-work or by-mail programs) in low- and moderate-income geographies and to low- and moderate-income individuals.
5. Assess the quantity, quality and accessibility of the institution's service-delivery systems
provided in low-, moderate-, middle-, and upper-income geographies. Consider the degree to which services are tailored to the convenience and needs of each geography (e.g., extended business hours, including weekends, evenings or by appointment, providing bi-lingual services in specific geographies, etc.). Community Development Services
6. Identify the institution's community development services including, at the institution's option,
services through affiliates. Hold discussions with management and review available materials. Determine:
a. Whether services have been considered under the lending or investments tests: and b. If provided by affiliates of the institution, services are not claimed by other affiliated institutions.

7. Evaluate performance using information obtained in the performance context procedures,
especially with regard to community needs and institutional capacity. Determine:
a. The extent of community development services provided in:
i. The institution’s assessment area(s); or
ii. The broader statewide or regional area that includes the assessment area(s) that
support organizations or activities with a purpose, mandate, or function that includes serving the geographies or individuals located within the institution’s assessment area(s). b. Their innovativeness, including whether they serve low- or moderate-income customers in new ways or serve groups of customers not previously served; and
c. The degree to which they serve low- or moderate-income areas or individuals and their
responsiveness to available opportunities for community development services.
8. If the institution has been responsive to community development needs and opportunities in its
assessment area(s) based on the analysis in step number 7, consider:
a. The extent of community development services in the broader statewide or regional area that includes the assessment area(s), but:
i. Will not benefit the assessment area(s); and
ii. Do not support organizations or activities with a purpose, mandate, or function that
includes serving geographies or individuals located within the institution’s assessment area(s). b. The extent to which these services enhance the institution’s performance. Note: Refer to the appendix for additional guidance on addressing activities at the state or multistate MSA, or institution level.
9. Discuss with management the preliminary findings.
10. Summarize conclusions about the institution's system for delivering retail banking and
community development services, considering:
a. The distribution of branches among low-, moderate-, middle-, and upper-income geographies; b. The institution's record of opening and closing branches, particularly branches located in low- or moderate-income geographies or primarily serving low- or moderate-income individuals;

c. The availability and effectiveness of alternative systems for delivering retail banking
services; d. The extent to which the institution provides community development services; e. The innovativeness and responsiveness of community development services; and f. The range and accessibility of services provided in low-, moderate-, middle-, and upper￾income geographies.
11. Prepare comments for the performance evaluation and the Compliance examination report.
Refer to the appendix for guidance on addressing community development activities in the performance evaluation. Ratings

1. Group the analyses of the assessment areas examined by MSA3 and nonmetropolitan areas
   within each state where the institution has branches. If an institution has branches in two or more states of a multistate MSA, group the assessment areas that are in that multistate MSA.
2. Summarize conclusions regarding the institution's performance in each MSA and
   nonmetropolitan portion of each state with an assessment area that was examined using these procedures. If two or more assessment areas in an MSA or in a nonmetropolitan portion of a state were examined using these procedures, determine the relative significance of the institution's performance in each assessment area by considering:
   a. The significance of the institution's lending, qualified investments, and lending-related services in each compared to:
   i. The institution's overall activities;
   ii. The number of other institutions and the extent of their activities; and
   iii. The lending, investment, and service opportunities in each.
   b. Demographic and economic conditions in each.
3. Evaluate the institution's performance in those assessment area(s) not selected for examination
   using the full-scope procedures.
   The reference to MSA may also reference MD.

a. Revisit the demographic and lending, investment, and service data considered in scoping the examination. Also, consider the institution's operations (branches, lending portfolio mix, etc.) in the assessment area(s). b. Through a review of the public file(s), consider any services that are customized to the assessment area(s).
c. Consider any other information provided by the institution (e.g., CRA self-assessment)
regarding its performance in the area.
4. For MSAs, and the nonmetropolitan portion of the state, where one or more assessment areas
were examined using the full-scope procedures, ensure that performance in the assessment area(s) not examined using the full-scope procedures is consistent with the conclusions based on the assessment area(s) examined in step 2, above. Select one of the following options for inclusion in the performance evaluation:
a. The institution's [lending, investment, service] performance in [the assessment area/these assessment areas] is consistent with the institution's [lending, investment, service] performance in the assessment areas within [the MSA/nonmetropolitan portion of the state] that were reviewed using the examination procedures. b. The institution's [lending/investment/service] performance in [the assessment area/these assessment areas] [exceeds/is below] the [lending/investment/service] performance in the assessment areas within [the MSA/nonmetropolitan portion of the state] that were reviewed using the examination procedures; however, it does not change the conclusion for the [MSA/nonmetropolitan portion of the state].
5. For MSA, and nonmetropolitan portions of the state, where no assessment area was examined
using the full-scope procedures, form a conclusion regarding the institution's lending, investment, and service performance in the assessment area(s). When there are several assessment areas in the MSA, or the nonmetropolitan portion of the state, form a conclusion regarding the institution's performance in the MSA, or the nonmetropolitan portion of the state. Determine the relative significance of the institution's performance in each assessment area within the MSA, or the nonmetropolitan portion of the state, by considering:
a. The significance of the institution's lending, qualified investments, and lending-related services in each compared to the institution's overall activities. b. Demographic and economic conditions in each.
6. Also, select one of the following options for inclusion in the performance evaluation:
a. The institution's [lending, investment, service] performance in [the assessment area/these assessment areas] is consistent with the institution's [lending, investment, service] performance [overall/in the state].

b. The institution's [lending/investment/service] performance in [the assessment area/these assessment areas] [exceeds/is below] the [lending/investment/service] performance for the [institution/state], however, it does not change the [institution's/state] rating.
7. Determine the relative significance of each MSA and nonmetropolitan area to the institution's
overall performance (institutions operating in one state) or statewide or multistate MSA performance (institutions operating in more than one state). Consider:
a. The significance of the institution's lending, qualified investments, and lending-related services in each compared to:
i. The institution's overall activities;
ii. The number of other institutions and the extent of their activities; and
iii. The lending, investment, and service opportunities in each.
b. Demographic and economic conditions in each.
8. When determining the state or multistate MSA rating, as applicable, consider:
a. Community development loans and services and qualified investments in the institution’s assessment area(s) in the state or multistate MSA; b. Community development loans and services and qualified investments:
i. In the broader statewide or regional area that includes the institution’s assessment
area(s) in the state or multistate MSA; and
ii. That support organizations or activities with a purpose, mandate, or function that
includes serving individuals or geographies in the institution’s assessment area(s); and
c. If the institution has been responsive to community development needs and opportunities
in its assessment area(s) based on the analysis in steps 8a and 8b, consider any community development loans and services and qualified investments in the broader statewide or regional area that includes the institution’s assessment area(s) in the state or multistate MSA that:
i. Will not benefit the assessment area(s); and
ii. Do not support organizations or activities with a purpose, mandate, or function that
includes serving geographies or individuals located within the institution’s assessment area(s).

9. Using the Component Test Ratings chart, below, assign component ratings that reflect the
institution's lending, investment, and service performance. In the case of an institution with branches in just one state, one set of component ratings will be assigned to the institution. In the case of an institution with branches in two or more states and multistate MSAs, component ratings will be assigned for each state or multistate MSA reviewed. COMPONENT TEST RATINGS Points for Lending Points for Investment Points for Service Outstanding 12 Points 6 Points 6 Points High Satisfactory 9 Points 4 Points 4 Points Low Satisfactory 6 Points 3 Points 3 Points Needs To Improve 3 Points 1 Point 1 Point Substantial Noncompliance 0 Points 0 Points 0 Points
10. Assign a preliminary composite rating for the institutions operating in only one state and a
preliminary rating for each state or multistate MSA reviewed for institutions operating in more than one state. In assigning the rating, sum the numerical values of the component test ratings for the lending, investment and service tests and refer to the chart, below. No institution, however, may receive an assigned rating of "Satisfactory" or higher unless it receives a rating of at least "Low Satisfactory" on the lending test. In addition, an institution's assigned rating can be no more than three times the score on the lending test. Composite Rating Points Needed Outstanding 20 Points or over Satisfactory 11 through 19 Points Needs To Improve 5 through 10 Points Substantial Noncompliance 0 through 4 Points
11. Consider an institution's past performance if the prior rating was "Needs to Improve." If the
poor performance has continued, an institution could be considered for a "Substantial Noncompliance" rating.
12. For institutions with branches in more than one state or multistate MSA, assign a preliminary
overall rating. a. To determine the relative importance of each state and multistate MSA to the institution's overall rating, consider:
i. The significance of the institution's lending, qualified investments, and lending￾related services in each compared to:
1. The institution's overall activities;
2. The number of other institutions and the extent of their activities in each; and
3. The lending, investment, and service opportunities in each.

ii. Demographic and economic conditions in each.
b. Consider the community development loans and services and qualified investments that meet the geographic requirements and that have not been considered in assigning state or multistate MSA ratings. For example, a qualified investment in a regional or nationwide fund that meets the geographic requirements and benefits more than one state, but was not considered because the benefits are not attributable to a particular state or multistate MSA, would be considered at the overall institution level.
13. Review the results of the most recent compliance examination and determine whether evidence
of discriminatory or other illegal credit practices that violate an applicable law, rule, or regulation should lower the institution's preliminary overall CRA rating, or the preliminary CRA rating for a state or multistate MSA.4 If evidence of discrimination or other illegal credit practices by the institution in any geography, or in any assessment area by any affiliate whose loans have been considered as part of the bank’s lending performance, was found, consider the following:
a. The nature, extent, and strength of the evidence of the practices; b. The policies and procedures that the institution (or affiliate, as applicable) has in place to prevent the practices;
c. Any corrective action the institution (or affiliate, as applicable) has taken, or has
committed to take, including voluntary corrective action resulting from self-assessment; and d. Any other relevant information.
14. Assign final overall rating to the institution. Consider:
a. The preliminary rating; and
15. Any evidence of discriminatory or other illegal credit practices, and discuss conclusions
with management.
16. Write comments and conclusions, and create charts and tables reflecting area demographics,
the institution's operation and its lending, investment and service activity in each assessment area for inclusion in the performance evaluation. 4 “Evidence of discriminatory or other illegal credit practices” includes, but is not limited to: (a) Discrimination against applicants on a prohibited basis in violation, for example, of the Equal Credit Opportunity Act or the Fair Housing Act; (b) Violations of the Home Ownership and Equity Protection Act; (c) Violations of section 5 of the Federal Trade Commission Act; (d) Violations of section 8 of the Real Estate Settlement Procedures Act; and (e) Violations of the Truth in Lending Act regarding a consumer’s right of rescission.

17. Prepare recommendations for supervisory strategy and matters that require attention for
follow-up activities.
Public File Checklist
1. There is no need to review each branch or each complete public file during every examination.
In determining the extent to which the institution's public files will be reviewed, consider the institution's record of compliance with the public file requirements in previous examinations; its branching structure and changes to it since its last examination; complaints about the institution's compliance with the public file requirements, and any other relevant information.
2. In any review of the public file undertaken, determine, as needed, whether branches display an
accurate public notice in their lobbies and the file(s) in the main office and in each state contains:
a. All written comments from the public relating to the institution's CRA performance and responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution); b. The institution's most recent CRA performance evaluation;
c. A map of each assessment area showing its boundaries, and on the map or in a separate
list, the geographies contained within the assessment area; d. A list of the institution's branches, branches opened and closed during the current and each of the prior two calendar years, and their street addresses and geographies; e. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution's branches), including a description of any material differences in the availability or cost of services between these locations; f. The institution's CRA disclosure statements for the prior two calendar years; g. A quarterly report of the institution's efforts to improve its record if it received a less than satisfactory rating in its most recent CRA performance evaluation; h. The HMDA Disclosure Statement for the prior two calendar years for the institution and for each non-depository affiliate the institution has elected to include in assessment of its CRA record, if applicable; and
i. If applicable, the number and amount of consumer loans made to the four income
categories of borrowers and geographies (low, moderate, middle and upper), and the number and amount located inside and outside of the assessment area(s).

3. In any branch review undertaken, determine whether the branch provides the most recent
performance evaluation and a list of services generally available at its branches and a description of any material differences in availability or cost of services at the branch (or a list of services available at the branch).

Appendix to Large Institution CRA Examination Procedures
Community Development Loans and Services and Qualified Investments Qualified community development (CD) activities in the assessment area (AA) or the broader statewide or regional area that includes the AA(s) Has a purpose, mandate, or function that includes serving the AA Does not have a purpose, mandate, or function that includes serving the AA Initial level activity is considered during the evaluation:
Specific AA when an activity benefits and is targeted to the AA.
State/Multistate MSA when an activity benefits or is targeted to two or more AAs, or the state or multistate MSA. Institution level when an activity benefits or is targeted to:

• A regional area of two or more states not in a
  multistate MSA, or
• A regional area that includes, but is larger
  than one multistate MSA.
  If the institution has been responsive to CD needs and opportunities in its AA(s), these activities may enhance performance at the state, multistate MSA, or institution level as applicable. State/Multistate MSA when the activity benefits geographies or individuals located in a state or multistate MSA where the bank has one or more defined AA. Institution level when the activity is in the broader regional area that includes the bank’s AA(s). Note: It is not appropriate to assign activities to a specific AA or state unless the bank can demonstrate the activity benefitted, and was targeted to, the AA or state. PE comments:
  Specific AA – Discuss conclusions regarding evaluation of the level of activity. Comment on the quantitative measure of the loan/investment/service and the qualitative aspects that augmented performance levels. State/Multistate MSA – Discuss conclusions regarding evaluation of the level of activity. Comment on the quantitative measure of all loans, investments, and services in all the AA(s) in the state or multistate MSA combined. Include statewide and regional activities that contribute to the state/multistate MSA’s overall assessment and indicate if related amounts are in addition to or included in specific AA discussions or tables. Explain if loans, investments, and/or services for any AA were given greater weight than others and why. Comment generally on qualitative aspects that augmented performance, such as responsiveness to need, degree of innovation, or complexity. Institution level – Discuss conclusions regarding evaluation of the level of activity. Comment on the quantitative measure of all loans, investments, and services in all states and multistate MSAs combined. Include regional and nationwide activities that contribute to the institution’s overall assessment and indicate if related amounts are in addition to or included in the specific state or multistate MSA discussions or tables. Explain if loans, investments, and/or services for any state or multistate MSA were given greater weight than others and why. Comment generally on qualitative aspects that augmented performance, such as responsiveness to need, degree of innovation, or complexity. Show in tables (when used):
  Specific AA - Include qualified activities the bank can demonstrate directly benefit or target the AA. State/Multistate MSA – Separate line for qualified activities that support an organization or activity that covers an area that is larger than, but includes the institution’s AA, and has not been attributed to a specific AA. Include regional activities and nationwide investments that benefit, or are targeted, to a specific state or multistate MSA. Institution level – Separate lines for 1) regional and 2) nationwide activities that were not otherwise attributed to a specific AA, state, or multistate MSA.

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Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
COMMUNITY REINVESTMENT ACT
EXAMINATION PROCEDURES FOR SMALL 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 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 (Footnote 1. The Board of Governors of the Federal Reserve System, The Federal Deposit Insurance Corporation, and The Office of the Comptroller of the Currency) based on (a) rates of poverty, unemployment, and population loss or (b) population size, density, and dispersion;(Footnote 2. A list of distressed or underserved nonmetropolitan middle-income geographies is available on the FFIEC web site at www.ffiec.gov.)
   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 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

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006 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. 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), Uniform Bank
Performance Reports (UBPR), annual reports, supervisory reports, and prior CRA evaluations of the institution under examination. Review financial information and the prior CRA evaluations of institutions of similar size that serve the same or similar assessment area(s).
3. Consider any information the institution may provide on its local community and
economy, its business strategy, its lending capacity, or 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. Refer to the Community Contact Procedures for more detail.
5. Review the institution’s public file for 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 performance.
Assessment Area
1. Review the institution’s stated assessment area(s) to ensure that it:
a. Consists of one or more MSAs/MDs or contiguous political subdivisions (e.g., counties, cities, or towns);

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006 b. Includes the geographies where the institution has its main office, branches, and deposit-taking ATMs, as well as the surrounding geographies in which the institution originated or purchased a substantial portion of its loans;
c. Consists only of whole census tracts;
d. Consists of separate delineations for areas that extend substantially across MSA/MD or state boundaries unless the assessment area is located in a multi￾state MSA/MD; e. Does not reflect illegal discrimination; and f. Does not arbitrarily exclude any low- or moderate-income area(s), taking into account the institution’s size, branching structure, and financial condition.
2. If an institution's assessment area(s) does not coincide with the boundaries of an
MSA/MD or political subdivision(s), assess whether the adjustments to the boundaries were made because the assessment area would otherwise be too large for the institution to reasonably serve, have an unusual configuration, or include significant geographic barriers.
3. If the assessment area(s) fails to comply with the applicable criteria described above,
develop, based on discussions with management, a revised assessment area(s) that complies with the criteria. Use this assessment area(s) to evaluate the institution’s performance, but do not otherwise consider the revision in determining the institution’s rating. Performance Criteria Loan-to-Deposit Analysis

1. From data contained in Call Reports or UBPRs, calculate the average loan-to-deposit
   ratio since the last examination by adding the quarterly loan-to-deposit ratios and dividing by the number of quarters.
2. Evaluate whether the institution's average loan-to-deposit ratio is reasonable in light of
   information from the performance context including, as applicable, the institution's capacity to lend, the capacity of other similarly-situated institutions to lend in the assessment area(s), demographic and economic factors present in the assessment area(s), and the lending opportunities available in the institution's assessment area(s).

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
3. If the loan to deposit ratio does not appear reasonable in light of the performance context,
consider the number and the dollar volume of loans sold to the secondary market, or the innovativeness or complexity of community development loans and qualified investments to assess the extent to which these activities compensate for a low loan-to-deposit ratio or supplement the institution's lending performance as reflected in its loan-to-deposit ratio.
4. Discuss the preliminary findings in this section with management.
5. Summarize in workpapers conclusions regarding the institution's loan-to-deposit ratio.
Comparison of Credit Extended Inside and Outside of the Assessment Area(s)

1. If available, review HMDA data, automated loan reports, and any other reports that may
   have been generated by the institution to analyze the extent of lending inside and outside of the assessment area(s). If a report generated by the institution is used, test the accuracy of the output.
2. If loan reports or data analyzing lending inside and outside of the assessment area(s) are
   not available or comprehensive, or if their accuracy cannot be verified, use sampling guidelines to select a sample of loans originated, purchased or committed to calculate the percentage (by number and dollar amount) located within the assessment area(s).
3. If the percentage of loans or other lending related activities in the assessment area is less
   than a majority, then the institution does not meet the standards for “Satisfactory” under this performance criterion. In this case, consider information from the performance context, such as information about economic conditions, loan demand, the institution’s size, financial condition, branching network, and business strategies when determining the effect of not meeting the standards for satisfactory for this criterion on the overall rating for the institution.
4. Discuss the preliminary findings in this section with management.
5. Summarize in workpapers conclusions regarding the institution's level of lending or other
   lending related activities inside and outside of its assessment area(s). Distribution of Credit Within the Assessment Area(s)

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006

1. Determine whether the number and income distribution of geographies in the assessment
   area(s) are sufficient for a meaningful analysis of the geographic distribution of the institution’s loans in its assessment area(s).
2. If a geographic distribution analysis of the institution’s loans would be meaningful and
   the necessary geographic information (street address or census tract numbers) is collected by the institution in the ordinary course of its business, determine the distribution of the institution’s loans in its assessment area(s) among low-, moderate-, middle-, and upper￾income geographies. Where possible, use the same loan reports, loan data, or sample used to compare credit extended inside and outside the assessment area(s).
3. If a geographic analysis of loans in the assessment area(s) is performed, identify groups
   of geographies, by income categories, in which there is little or no loan penetration. Note that institutions are not expected to lend in every geography.
4. To the extent information about borrower income (individuals) or revenues (businesses)
   is collected by the institution in the ordinary course of its business, determine the distribution of loans in the assessment area(s) by borrower income and by business revenues. Where possible, use the same loan reports, loan data, or sample used to compare credit extended inside and outside the assessment area(s).
5. Identify categories of borrowers by income or business revenue for which there is little or
   no loan penetration.
6. If an analysis of the distribution of loans among geographies of different income levels
   would not be meaningful (e.g., very few geographies in the assessment area(s)) or an analysis of lending to borrowers of different income or revenues could not be performed (e.g., income data are not collected for certain loans), consider possible proxies to use for analysis of the institution’s distribution of credit. Possibilities include analyzing geographic distribution by street address rather than geography (if data are available and the analysis would be meaningful) or analyzing the distribution by loan size as a proxy for income or revenues of the borrower.
7. If there are categories of low penetration, form conclusions about the reasons for that low
   penetration. Consider available information from the performance context, including:
   a. Information about the institution’s size, branch network, financial condition, supervisory restrictions (if any) and prior CRA record; b. Information from discussions with management, loan officers, and members of

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006 the community;
c. Information about economic conditions, particularly in the assessment area(s);
d. Information about demographic or other characteristics of particular geographies that could affect loan demand, such as the existence of a prison or college; and e. Information about other lenders serving the same or similar assessment area(s).
8. Discuss the preliminary findings in this section with management.
9. Summarize in workpapers conclusions concerning the geographic distribution of loans
and the distribution of loans by borrower characteristics in the institution’s assessment area(s). Review of Complaints
1. Review all complaints relating to the institution's CRA performance received by the
institution (these should all be contained in the institution's public file) and those that were received by its supervisory agency.
2. If there were any complaints, evaluate the institution's record of taking action, if
warranted, in response to written complaints about its CRA performance.
3. If there were any complaints, discuss the preliminary findings in this section with
management.
4. If there were any complaints, summarize in workpapers conclusions regarding the
institution's record of taking action, if warranted, in response to written complaints about its CRA performance. Include the total number of complaints and resolutions with examples that illustrate the nature, responsiveness to, and resolution of, the complaints. Investments and Services (at the institution’s option to enhance a “Satisfactory” rating)
1. If the institution chooses, review its performance in making qualified investments and
providing branches and other services and delivery systems that enhance credit availability in its assessment area(s). Performance with respect to qualified investments and services may be used to enhance an institution’s overall rating of “Satisfactory”, but cannot be used to lower a rating that otherwise would have been assigned.

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
2. To evaluate the institution's performance in making qualified investments that enhance
credit availability in its assessment area(s), consider:
a. The dollar amount of qualified investments, by type and location; b. The impact of those investments on the institution's assessment area(s); and
c. The innovativeness or complexity of the investments.
3. To evaluate the institution's record of providing branches and other services and delivery
systems that enhance credit availability in its assessment area(s), consider:
a. The number of branches and ATMs located in the institution's assessment area(s); b. The number of branches and ATMs located within, or that are readily accessible to, low- and moderate-income geographies compared to those located in, or readily accessible to middle- and upper-income geographies;
c. The type and level of service(s) offered at branches and ATMs and alternative
delivery systems; and d. The institution’s record of opening and closing branches. Ratings

1. Group the analyses of the assessment areas examined by MSA (Footnote 3. The reference to MSA may also reference MD) and nonmetropolitan
   areas within each state where the institution has branches. If an institution has branches in two or more states of a multi-state MSA, group the assessment areas that are in that MSA.
2. Summarize conclusions about the institution’s performance in each MSA and the
   nonmetropolitan portion of each state in which an assessment area received a full scope review. If two or more assessment areas in an MSA or in the nonmetropolitan portion of a state received full scope reviews, weigh the different assessment areas considering such factors as:
   a. The significance of the institution’s activities in each compared to the institution’s overall activities;

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006 b. The lending opportunities in each;
c. The importance of the institution in providing loans to each, particularly in light
of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
3. For assessment areas in MSAs and nonmetropolitan areas that were not examined using
the full scope procedures, consider facts and data related to the institution’s lending to ensure that performance in those assessment areas is not inconsistent with the conclusions based on the assessment areas that received full scope examinations.
4. For institutions operating in only one multi-state MSA or one state, assign one of the four
preliminary ratings -- “Satisfactory”, “Outstanding”, “Needs to Improve”, and “Substantial Noncompliance” -- in accordance with step 6 below. To determine the relative significance of each MSA and nonmetropolitan area to the institution’s preliminary rating, consider:
a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The lending opportunities in each;
c. The importance of the institution in providing loans to each, particularly in light
of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
5. For other institutions, assign one of the four preliminary ratings – “Satisfactory”,
“Outstanding”, “Needs to Improve”, and “Substantial Noncompliance” -- for each state in which the institution has at least one branch and for each multi-state MSA in which the institution has branches in two or more states in accordance with step #6 below. To determine the relative significance of each MSA and the nonmetropolitan area on the institution’s preliminary state rating, consider:
a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The lending opportunities in each;

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
c. The importance of the institution in providing loans to each, particularly in light
of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
6. Consult the Small Institution Ratings Matrix and information in workpapers to assign a
preliminary rating of:
a. “Satisfactory” if the institution’s performance meets each of the standards for a satisfactory rating or if exceptionally strong performance with respect to some of the standards compensates for weak performance in others; b. "Needs to Improve" or "Substantial Noncompliance" if the institution's performance fails to meet the standards for "Satisfactory" performance. Whether a rating is "Needs to Improve" or "Substantial Noncompliance" will depend upon the degree to which the institution's performance has failed to meet the standards for a "Satisfactory" rating; or
c. "Outstanding" if the institution meets the rating descriptions and standards for
“Satisfactory” for each of the five core criteria, and materially exceeds the standards for “Satisfactory” in some or all of the criteria to the extent that an outstanding rating is warranted, or if the institution's performance with respect to the five core criteria generally exceeds “Satisfactory” and its performance in making qualified investments and providing branches and other services and delivery systems in the assessment area(s) supplement its performance under the five core criteria sufficiently to warrant an overall rating of “Outstanding”.
7. For an institution with branches in more than one state or multi-state MSA, assign a
preliminary rating to the institution as a whole taking into account the institution’s record in different states or multi-state MSAs by considering:
a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The lending opportunities in each;
c. The importance of the institution in providing loans to each, particularly in light
of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
8. Review the results of the most recent compliance examination and determine whether
evidence of discriminatory or other illegal credit practices that violate an applicable law, rule, or regulation should lower the institution’s overall CRA rating or, if applicable, its CRA rating in any state or multi-state MSA. (Footnote 4. “Evidence of discriminatory or other illegal credit practices” includes, but is not limited to: (a) Discrimination against applicants on a prohibited basis in violation, for example, of the Equal Credit Opportunity Act or the Fair Housing Act; (b) Violations of the Home Ownership and Equity Protection Act; (c) Violations of section 5 of the Federal Trade Commission Act; (d) Violations of section 8 of the Real Estate Settlement Procedures Act; and (e) Violations of the Truth in Lending Act regarding a consumer’s right of rescission.) If evidence of discrimination or other illegal credit practices in any geography by the institution, or in any assessment area by any affiliate whose loans have been considered as part of the institution’s lending performance, was found, consider:
a. The nature, extent, and strength of the evidence of the practices; b. The policies and procedures that the institution (or affiliate, as applicable) has in place to prevent the practices;
c. Any corrective action the institution (or affiliate, as applicable) has taken, or has
committed to take, including voluntary corrective action resulting from self￾assessment; and d. Any other relevant information.
9. Assign a final rating for the institution as a whole and, if applicable, each state in which
the institution has at least one branch and each multi-state MSA in which it has branches in two or more states, considering:
a. The institution’s preliminary rating; and b. Any evidence of discriminatory or other illegal credit practices (see #8 above).
10. Discuss conclusions with management.
11. Write an evaluation of the institution’s performance for the examination report and the
public evaluation.
12. Prepare recommendations for a supervisory strategy and for matters that require attention
or follow-up activities.

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
Public File Checklist

1. There is no need to review each branch or each complete public file during every
   examination. In determining the extent to which the institution’s public files should be reviewed, consider the institution’s record of compliance with the public file requirements in previous examinations, its branching structure and changes to it since its last examination, complaints about the institution’s compliance with the public file requirements, and any other relevant information.
2. In any review of the public file undertaken, determine, as needed, whether branches
   display an accurate public notice in their lobbies, a complete public file is available in the institution’s main office and at least one branch in each state, and the public file available in the main office and in a branch in each state contains:
   a. All written comments from the public relating to the institution's CRA performance and responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution); b. The institution's most recent CRA Public Performance Evaluation;
   c. A map of each assessment area showing its boundaries and, on the map or in a
   separate list, the geographies contained within the assessment area; d. A list of the institution's branches, branches opened and closed during the current and each of the prior two calendar years, and their street addresses and geographies; e. The HMDA Disclosure Statement for the prior two calendar years, if applicable; f. The institution's loan-to-deposit ratio for each quarter of the prior calendar year; g. A quarterly report of the institution's efforts to improve its record if it received a less than satisfactory rating during its most recent CRA examination; and h. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution’s branches), including a description of any material differences in the availability or cost of services among locations.
3. In any branch review undertaken, determine whether the branch provides the most recent

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006 public evaluation and a list of services available at the branch or a description of material differences from the services generally available at the institution’s other branches.

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006
CRA RATINGS MATRIX - SMALL INSTITUTIONS
CHARACTERISTIC column heading OUTSTANDING column heading SATISFACTORY column heading NEEDS TO IMPROVE column heading SUBSTANTIAL NONCOMPLIANCE column heading Loan-to-deposit ratio OUTSTANDING Loan-to-deposit ratio - The loan-to-deposit ratio is more than reasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. SATISFACTORY - Loan-to-deposit ratio The loan-to-deposit ratio is reasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. NEEDS TO IMPROVE - Loan-to-deposit ratio The loan-to-deposit ratio is less than reasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. SUBSTANTIAL NONCOMPLIANCE - Loan-to-deposit ratio The loan-to-deposit ratio is unreasonable (considering seasonal variations and taking into account lending related activities) given the institution’s size, financial condition, and assessment area credit needs. Assessment area(s) concentration OUTSTANDING - Assessment area(s) concentration A substantial majority of loans and other lending related activities are in the institution’s assessment area(s). SATISFACTORY - Assessment area(s) concentration A majority of loans and other lending related activities are in the institution’s assessment area(s). NEEDS TO IMPROVE -Assessment area(s) concentration A majority of loans and other lending related activities are outside the institution’s assessment area(s). SUBSTANTIAL NONCOMPLIANCE - Assessment area(s) concentration A substantial majority of loans and other lending related activities are outside the institution’s assessment area(s). Geographic distribution of loans OUTSTANDING The geographic distribution of loans reflects excellent dispersion throughout the assessment area(s). SATISFACTORY The geographic distribution of loans reflects reasonable dispersion throughout the assessment area(s). NEEDS TO IMPROVE The geographic distribution of loans reflects poor dispersion throughout the assessment area(s). SUBSTANTIAL NONCOMPLIANCE The geographic distribution of loans reflects very poor dispersion throughout the assessment area(s). Borrower’s profile OUTSTANDING - Borrower’s profile The distribution of borrowers reflects, given the demographics of the assessment area(s), excellent penetration among individuals of different income levels (including low￾and moderate-income) and businesses of different sizes. SATISFACTORY - Borrower’s profile The distribution of borrowers reflects, given the demographics of the assessment area(s), reasonable penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. NEEDS TO IMPROVE - Borrower’s profile The distribution of
borrowers reflects, given the demographics of the assessment area(s), poor penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. SUBSTANTIAL NONCOMPLIANCE - Borrower’s profile The distribution of borrowers reflects, given the demographics of the assessment area(s), very poor penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. Response to substantiated complaints OUTSTANDING - Response to substantiated complaints The institution has taken noteworthy, creative action in response to substantiated complaints about its performance in meeting assessment area credit needs. SATISFACTORY - Response to substantiated complaints The institution has taken appropriate action in response to substantiated complaints about its performance in meeting assessment area credit needs. NEEDS TO IMPROVE - Response to substantiated complaints The institution has taken inadequate action in response to substantiated complaints about its performance in meeting assessment area credit needs. SUBSTANTIAL NONCOMPLIANCE - Response to substantiated complaints The institution is unresponsive to substantiated complaints about its performance in meeting assessment area credit needs. Investments OUTSTANDING - Investments The institution’s investment record enhances credit availability in its assessment area. SATISFACTORY - Investments N/A NEEDS TO IMPROVE - Investments N/A SUBSTANTIAL NONCOMPLIANCE - Investments N/A Services OUTSTANDING - Services The institution’s record of providing branches, ATMs, loan production offices, and/or other services and delivery systems enhances credit availability in its assessment area(s). SATISFACTORY - Services N/A NEEDS TO IMPROVE - Services N/A SUBSTANTIAL NONCOMPLIANCE - Services N/A

Small Institution CRA Examination Procedures
OCC, FRB, FDIC February 2006

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Examination Scope
For institutions (interstate and intrastate) with more than one assessment area, identify assessment areas for a full scope review. A full scope review is accomplished when examiners complete all of the procedures for an assessment area. For interstate institutions, a minimum of one assessment area from each state, and a minimum of one assessment area from each multistate MSA/MD, must be reviewed using the full scope examination procedures.

1. To identify assessment areas for full scope review, 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 retail lending and community development opportunities in the different assessment areas, particularly areas where the need for credit and community development activities is significant; b. The level of the institution’s activity in the different assessment areas, including in low- and moderate-income areas, designated disaster areas, or distressed or underserved non-metropolitan middle-income geographies designated by the Agencies (Footnote 1. The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency.) based on (a) rates of poverty, unemployment, and population loss or (b) population size, density, and dispersion; (Footnote 2. A list of distressed or undeserved non-metropolitan middle-income geographies will be made available on the FFIEC web site at www.ffiec.gov.)
   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 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; Intermediate Small Institution Examination Procedures Interagency Intermediate Small Institution Examination Procedures 8-1-05 Revision history: On June 2, 2026: Reputation risk is no longer a component of federal examination programs. See, e.g., Federal Reserve press release, OCC bulletin, and FDIC Financial Institution Letter.

Interagency Intermediate Small Institution Examination Procedures 8-1-05 g. Examiners’ knowledge of the same or similar assessment areas; and h. Comments from the public regarding the institution’s CRA performance.
2. Select one or more assessment areas in each state, and one or more
assessment areas in any multi-state MSA, for examination using these procedures. This is required because for interstate institutions, a rating must be assigned for each state where the institution has a branch and for each multi￾state MSA/MD where the institution has branches in two or more states that comprise that MSA/MD. 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), Uniform
   Bank Performance Reports (UBPRs), 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 safe and sound opportunities in the assessment area(s) for retail loans, and community development loans, qualified investments and community development services.
3. Discuss with the institution, 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. Refer 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

Interagency Intermediate Small Institution Examination Procedures 8-1-05 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. Assessment Area

1. Review the institution’s stated assessment area(s) to ensure that it:
   a. Consists of one or more MSAs/MDs or contiguous political subdivisions (e.g., counties, cities, or towns); b. Includes the geographies where the institution has its main office, branches, and deposit-taking ATMs, as well as the surrounding geographies in which the institution originated or purchased a substantial portion of its loans;
   c. Consists only of whole census tracts;
   d. Consists of separate delineations for areas that extend substantially across MSA/MD or state boundaries unless the assessment area is located in a multistate MSA/MD; e. Does not reflect illegal discrimination; and f. Does not arbitrarily exclude any low- or moderate-income area(s), taking into account the institution’s size, branching structure, and financial condition.
2. If an institution’s assessment area(s) does not coincide with the boundaries of an
   MSA/MD or political subdivision(s), assess whether the adjustments to the

Interagency Intermediate Small Institution Examination Procedures 8-1-05 boundaries were made because the assessment area would otherwise be too large for the institution to reasonably serve, have an unusual configuration, or include significant geographic barriers.
3. If the assessment area(s) fails to comply with the applicable criteria described
above, develop, based on discussions with management, a revised assessment area(s) that complies with the criteria. Use this assessment area(s) to evaluate the institution’s performance, but do not otherwise consider the revision in determining the institution’s rating. Intermediate Small Institution Lending Test Performance Criteria Loan-to-Deposit Analysis
1. From data contained in Call Reports or UBPRs, calculate the average loan-to￾deposit ratio since the last examination by adding the quarterly loan-to-deposit
ratios and dividing by the number of quarters.
2. Evaluate whether the institution’s average loan-to-deposit ratio is reasonable in
light of information from the performance context including, as applicable, the institution’s capacity to lend, the capacity of other similarly situated institutions to lend in the assessment area(s), demographic and economic factors present in the assessment area(s), and the lending opportunities available in the institution’s assessment area(s).
3. If the loan-to-deposit ratio does not appear reasonable in light of the performance
context, consider whether the number and the dollar amount of loans sold to the secondary market compensate for a low loan-to-deposit ratio or supplement the institution’s lending performance.
4. Summarize in work papers conclusions regarding the institution’s loan-to-deposit
ratio.
Comparison of Credit Extended Inside and Outside of the Assessment Area(s)
1. If available, review HMDA data, automated loan reports, and any other reports
that may have been generated by the institution to analyze the extent of lending inside and outside of the assessment area(s). If a report generated by the institution is used, test the accuracy of the output.
2. If loan reports or data analyzing lending inside and outside of the assessment
area(s) are not available or comprehensive, or if their accuracy cannot be verified, use sampling guidelines to select a sample of loans originated, purchased or committed to calculate the percentage (by number and dollar volume) located within the assessment area(s).

Interagency Intermediate Small Institution Examination Procedures 8-1-05
3. If the percentage of loans or other lending related activities in the assessment
area is less than a majority, then the institution does not meet the standards for “Satisfactory” under this performance criterion. In this case, consider information from the performance context, such as information about economic conditions, loan demand, the institution’s size, financial condition, branching network, and business strategies when determining the effect of not meeting the standards for satisfactory for this criterion on the overall rating for the institution.
4. Summarize in work papers conclusions regarding the institution’s level of lending
or other lending related activities inside and outside of its assessment area(s). Distribution of Credit within the Assessment Area(s)

1. Determine whether the number and income distribution of geographies in the
   assessment area(s) are sufficient for a meaningful analysis of the geographic distribution of the institution’s loans in its assessment area(s).
2. If a geographic distribution analysis of the institution’s loans would be meaningful
   and the necessary geographic information (street address or census tract number) is collected by the institution in the ordinary course of its business, determine the distribution of the institution’s loans in its assessment area(s) among low-, moderate-, middle-, and upper-income geographies. Where possible, use the same loan reports, loan data, or sample used to compare credit extended inside and outside the assessment area(s).
3. If a geographic analysis of loans in the assessment area(s) is performed, identify
   groups of geographies, by income categories, in which there is little or no loan penetration. Note that institutions are not expected to lend in every geography.
4. To the extent information about borrower income (individuals) or revenues
   (businesses) is collected by the institution in the ordinary course of its business, determine the distribution of loans in the assessment area(s) by borrower income and by business revenues. Where possible, use the same loan reports, loan data, or sample used to compare credit extended inside and outside the assessment area(s).
5. Identify categories of borrowers by income or business revenue for which there is
   little or no loan penetration.
6. If an analysis of the distribution of loans among geographies of different income
   levels would not be meaningful (e.g., very few geographies in the assessment area(s)) or an analysis of lending to borrowers of different income or revenues could not be performed (e.g., income data are not collected for certain loans), consider possible proxies to use for analysis of the institution’s distribution of credit. Possibilities include analyzing geographic distribution by street address rather than geography (if data are available and the analysis would be

Interagency Intermediate Small Institution Examination Procedures 8-1-05 meaningful) or analyzing the distribution by loan size as a proxy for income or revenue of the borrower.
7. If there are categories of low penetration, form conclusions about the reasons for
that low penetration. Consider available information from the performance context, including:
a. Information about the institution’s size, branch network, financial condition, supervisory restrictions (if any) and prior CRA record; b. Information from discussions with management, loan officers, and members of the community;
c. Information about economic conditions, particularly in the assessment
area(s); d. Information about demographic or other characteristics of particular geographies that could affect loan demand, such as the existence of a prison or college; and e. Information about other lenders serving the same or similar assessment area(s).
8. Summarize in work papers conclusions concerning the geographic distribution of
loans and the distribution of loans by borrower characteristics in the institution’s assessment area(s). Review of Complaints

1. Review all complaints relating to the institution’s CRA performance received by
   the institution (these should all be contained in the institution’s public file) and those that were received by its supervisory agency.
2. If there were any complaints, evaluate the institution’s record of taking action, if
   warranted, in response to written complaints about its CRA performance.
3. If there were any complaints, discuss the preliminary findings in this section with
   management.
4. If there were any complaints, summarize in work papers conclusions regarding
   the institution’s record of taking action, if warranted, in response to written complaints about its CRA performance. Include the total number of complaints and resolutions with examples that illustrate the nature, responsiveness to, and resolution of, the complaints.
5. Discuss the preliminary findings in the lending test section with management.

Interagency Intermediate Small Institution Examination Procedures 8-1-05 INTERMEDIATE SMALL INSTITUTION LENDING TEST RATINGS MATRIX CHARACTERISTIC colum heading OUTSTANDING column heading SATISFACTORY column heading NEEDS TO IMPROVE column heading SUBSTANTIAL NONCOMPLIANCE column heading Loan-to-deposit ratio row heading Loan-to-deposit ratio - OUTSTANDING The loan-to-deposit ratio is more than reasonable (considering seasonal variations and taking into account lending-related activities) given the institution’s size, financial condition, and assessment area credit needs. Loan-to-deposit ratio - SATISFACTORY The loan-to-deposit ratio is reasonable (considering seasonal variations and taking into account lending-related activities) given the institution’s size, financial condition, and assessment area credit needs. Loan-to-deposit ratio - NEEDS TO IMPROVE The loan-to-deposit ratio is less than reasonable (considering seasonal variations and taking into account lending-related activities) given the institution’s size, financial condition, and assessment area credit needs. Loan-to-deposit ratio - SUBSTANTIAL NONCOMPLIANCE The loan-to-deposit ratio is unreasonable (considering seasonal variations and taking into account lending-related activities) given the institution’s size, financial condition, and assessment area credit needs. Assessment area(s) concentration Assessment area(s) concentration - OUTSTANDING A substantial majority of loans and other lending related activities are in the institution’s assessment area(s). Assessment area(s) concentration - SATISFACTORY A majority of loans and other lending related activities are in the institution’s assessment area(s). Assessment area(s) concentration - NEEDS TO IMPROVE A majority of loans and other lending related activities are outside the institution’s assessment area(s). Assessment area(s) concentration - SUBSTANTIAL NONCOMPLIANCE A substantial majority of loans and other lending related activities are outside the institution’s assessment area(s). Geographic distribution of loans Geographic distribution of loans - OUTSTANDING The geographic distribution of loans reflects excellent dispersion throughout the assessment area(s). Geographic distribution of loans - SATISFACTORY The geographic distribution of loans reflects reasonable dispersion throughout the assessment area(s). Geographic distribution of loans - NEEDS TO IMPROVE The geographic distribution of loans reflects poor dispersion throughout the assessment area(s). Geographic distribution of loans - SUBSTANTIAL NONCOMPLIANCE The geographic distribution of loans reflects very poor dispersion throughout the assessment area(s). Borrower’s profile Borrower’s profile - OUTSTANDING The distribution of borrowers reflects, given the demographics of the assessment area(s), excellent penetration among individuals of different income levels (including low￾and moderate-income) and businesses of different sizes. Borrower’s profile - SATISFACTORY The
distribution of borrowers reflects, given the demographics of the assessment area(s), reasonable penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. Borrower’s profile - NEEDS TO IMPROVE The distribution of borrowers reflects, given the demographics of the assessment area(s), poor penetration among individuals of different income levels (including low- and moderate-income) and businesses of different sizes. Borrower’s profile - SUBSTANTIAL NONCOMPLIANCE The distribution of borrowers reflects, given the demographics of the assessment area(s), very poor penetration among individuals of different income levels (including low- and moderate￾income) and businesses of different sizes. Response to substantiated complaints Response to substantiated complaints - OUTSTANDING The institution has taken noteworthy, creative action in response to substantiated complaints about its performance in meeting assessment area credit needs. Response to substantiated complaints - SATISFACTORY The institution has taken appropriate action in response to substantiated complaints about its performance in meeting assessment area credit needs. Response to substantiated complaints - NEEDS TO IMPROVE The institution has taken inadequate action in response to substantiated complaints about its performance in meeting assessment area credit needs. Response to substantiated complaints - SUBSTANTIAL NONCOMPLIANCE The institution is unresponsive to substantiated complaints about its performance in meeting assessment area credit needs.

Interagency Intermediate Small Institution Examination Procedures 8-1-05 Intermediate Small Institution Community Development Test An institution should appropriately assess the needs in its community, engage in different types of community development activities based on those needs and the institution’s capacities, and take reasonable steps to apply its community development resources strategically to meet those needs. The flexibility inherent in the community development test allows intermediate small institutions to focus on meeting the substance of community needs through these activities. Examiners will consider the results of any assessment by the institution of community needs along with information from community, government, civic, and other sources to gain a working knowledge of community needs.

1. Identify the number and amount of the institution’s community development loans,
   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 number and amount of community development loans and qualified investments; b. The extent to which the institution provides community development services, including the provision and availability of services to low- and moderate-income people, including through branches and other facilities in low- and moderate￾income areas.

Interagency Intermediate Small Institution Examination Procedures 8-1-05
c. The responsiveness to the opportunities for community development lending,
qualified investments, and community development services, considering:
1) The results of any assessment of community development needs and
opportunities provided by the institution;
2) The examiner’s review of performance context information from
community, government, civic, and other sources; and
3) Whether the amount and combination of community development loans,
qualified investments, and community development services, along with their qualitative aspects, are responsive to community needs and opportunities.
5. Summarize conclusions regarding the institution’s community development
performance and retain in the work papers.
INTERMEDIATE SMALL INSTITUTION COMMUNITY DEVELOPMENT TEST RATING MATRIX OUTSTANDING column heading SATISFACTORY column heading NEEDS TO IMPROVE column heading SUBSTANTIAL NONCOMPLIANCE column heading OUTSTANDING The institution’s community development performance demonstrates excellent responsiveness to community development needs in its assessment area(s) through community development loans, qualified investments, and community development services, as appropriate, considering the institution’s capacity and the need and availability of such opportunities for community development in the institution’s assessment area(s). SATISFACTORY The institution’s community development performance demonstrates adequate responsiveness to the community development needs of its assessment area(s) through community development loans, qualified investments, and community development services, as appropriate, considering the institution's capacity and the need and availability of such opportunities for community development in the institution’s assessment area(s). NEEDS TO IMPROVE The institution’s community development performance demonstrates poor responsiveness to the community development needs of its assessment area(s) through community development loans, qualified investments, and community development services, as appropriate, considering the institution's capacity and the need and availability of such opportunities for community development in the institution’s assessment area(s). SUBSTANTIAL NONCOMPLIANCE The institution’s community development performance demonstrates very poor responsiveness to the community development needs of its assessment area(s) through community development loans, qualified investments, and community development services, as appropriate, considering the institution's capacity and the need and availability of such opportunities for community development in the institution’s assessment area(s).

Interagency Intermediate Small Institution Examination Procedures 8-1-05 Overall Intermediate Small Institution CRA Rating

1. Group the analyses of the assessment areas examined by MSA (Footnote 3. The reference to MSA may also reference MD.) and non-MSA
   areas within each state where the institution has branches. If an institution has branches in two or more states of a multi-state MSA, group the assessment areas that are in that MSA.
2. Summarize conclusions about the institution’s performance in each MSA and the
   non-MSA portion of each state in which an assessment area received a full scope review. If two or more assessment areas in an MSA or in the non-MSA portion of a state received full scope reviews, weigh the different assessment areas considering such factors as:
   a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The retail lending and community development opportunities in each;
   c. The importance of the institution in providing loans and community
   development activities to each, particularly in light of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
3. For assessment areas in MSAs and non-MSA areas that were not examined
   using these procedures, consider facts and data related to the institution’s lending and community development activities to ensure that performance in those assessment areas is not inconsistent with the conclusions based on the assessment areas which received full scope reviews.
4. For institutions operating in only one multi-state MSA or one state, assign one of
   the four preliminary ratings – “Satisfactory,” “Outstanding,” “Needs to Improve,” or “Substantial Noncompliance” -- in accordance with step 6 below. To determine the relative significance of each MSA and non-MSA area to the institution’s preliminary rating, consider:
   a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The retail lending and community development opportunities in each;
   c. The importance of the institution to each, particularly in light of the number of
   other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.

Interagency Intermediate Small Institution Examination Procedures 8-1-05
5. For other institutions, assign one of the four preliminary ratings -- “Satisfactory,”
“Outstanding,” “Needs to Improve,” or “Substantial Noncompliance” -- for each state in which the institution has at least one branch and for each multi-state MSA in which the institution has branches in two or more states in accordance with step #6 below. To determine the relative significance of each MSA and the non-MSA area on the institution’s preliminary state rating, consider:
a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The retail lending and community development opportunities in each;
c. The importance of the institution in each, particularly in light of the number of
other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
6. Consult the intermediate small institution ratings matrices (lending and
community development) and information in work papers to assign a preliminary rating of:
a. “Satisfactory” if the institution’s performance is rated as “Satisfactory” in each test. b. “Needs to Improve” or “Substantial Noncompliance,” depending upon the degree to which the institution’s performance has failed to meet the standards for a “Satisfactory” rating on a test; or
c. “Outstanding” if the institution is rated an ”Outstanding” on both tests; or
“Outstanding” on one test and the extent to which the institution meets or exceeds the “Satisfactory” criteria on the other test.
7. For an institution with branches in more than one state or multi-state MSA,
assign a preliminary rating to the institution as a whole taking into account the institution’s record in different states or multi-state MSAs by considering:
a. The significance of the institution’s activities in each compared to the institution’s overall activities; b. The retail lending and community development opportunities in each;
c. The importance of the institution in providing loans to each, particularly in light
of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.

Interagency Intermediate Small Institution Examination Procedures 8-1-05
8. Review the results of the most recent compliance examination and determine
whether evidence of discriminatory or other illegal credit practices should lower the institution’s overall CRA rating or, if applicable, its CRA rating in any state or multi-state MSA. If evidence of discrimination or other illegal credit practices in any geography by the institution, or in any assessment area by any affiliate whose loans were considered as part of the institution’s lending performance, was found, consider:
a. The nature, extent, and strength of the evidence of the practices; b. The policies and procedures that the institution (or affiliate, as applicable) has in place to prevent the practices;
c. Any corrective action that the institution (or affiliate, as applicable) has taken,
or has committed to take, including voluntary corrective action resulting from self-assessment; and d. Any other relevant information.
9. Assign a final rating for the institution as a whole and, if applicable, each state in
which the institution has at least one branch and each multi-state MSA in which it has branches in two or more states, considering:
a. The institution’s preliminary rating; and b. Any evidence of discriminatory or other illegal credit practices.
10. Discuss conclusions with management.
11. Write an evaluation of the institution’s performance for the examination report
and the public evaluation.
12. Prepare recommendations for a supervisory strategy and for matters that
require attention or follow-up activities.
Public File Checklist

1. There is no need to review each branch or each complete public file during every
   examination. In determining the extent to which the institution’s public files should be reviewed, consider the institution’s record of compliance with the public file requirements in previous examinations, its branching structure and changes to it since its last examination, complaints about the institution’s compliance with the public file requirements, and any other relevant information.
2. In any review of the public file undertaken, determine whether branches display
   an accurate public notice in their lobbies, a complete public file is available in the

Interagency Intermediate Small Institution Examination Procedures 8-1-05 institution’s main office and at least one branch in each state, and the public file(s) in the main office and in each state contain:
a. All written comments from the public relating to the institution’s CRA performance and any responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution); b. The institution’s most recent CRA Performance Evaluation;
c. A map of each assessment area showing its boundaries and, on the map or
in a separate list, the geographies contained within the assessment area; d. A list of the institution’s branches, branches opened and closed during the current and each of the prior two calendar years, their street addresses and geographies; e. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution’s branches), including a description of any material differences in the availability or cost of services between those locations; f. The institution’s loan-to-deposit ratio for each quarter of the prior calendar year; g. A quarterly report of the institution’s efforts to improve its record if it received a less than satisfactory rating during its most recent CRA examination; and h. HMDA Disclosure Statements for the prior two calendar years for the institution and for each non-depository affiliate the institution has elected to include in assessment of its CRA record, if applicable.
3. In any branch review undertaken, determine whether the branch provides the
most recent public evaluation and a list of services generally available at its branches and a description of any material differences in the availability or cost of services at the branch (or a list of services available at the branch).

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OCC, FRB, FDIC February 2006
COMMUNITY REINVESTMENT ACT
EXAMINATION PROCEDURES FOR LIMITED PURPOSE AND WHOLESALE 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.

OCC, FRB, FDIC February 2006
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), the consolidated report of condition (Call Report), 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.
Assessment Area
1. Review the institution's stated assessment area(s) to ensure that it:
a. Consists of one or more MSAs/MDs or contiguous political subdivisions (i.e., counties, cities, or towns) where the institution has its main office, branches, and deposit-taking ATMs; b. Consists only of whole census tracts;

OCC, FRB, FDIC February 2006
c. Consists of separate delineations for areas that extend substantially across MSA/MD
or state boundaries unless the assessment area is located in a multistate MSA/MD; d. Does not reflect illegal discrimination; and e. Does not arbitrarily exclude any low- or moderate-income area(s) taking into account the institution's size and financial condition.
2. If the assessment area(s) does not coincide with the boundaries of an MSA/MD or
political subdivision(s), assess whether the adjustments to the boundaries were made because the assessment area would otherwise be too large for the institution to reasonably serve, have an unusual configuration, or include significant geographic barriers.
3. If the assessment area(s) fails to comply with the applicable criteria described above,
develop, based on discussions with management, a revised assessment area(s) that complies with the criteria. Use this assessment area(s) to evaluate the institution's performance, but do not otherwise consider the revision in determining the institution's rating. 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:

OCC, FRB, FDIC February 2006 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.
Ratings

1. Review the analyses of the institution's performance in each assessment area examined,
   considering only those community development activities that benefit the assessment area(s) and the broader statewide or regional area(s) that include the assessment area(s).
2. Group the analyses of the assessment areas examined by MSA (Footnote 1. The reference to MSA may also reference MD.) and nonmetropolitan
   areas within each state where the institution has branches. If an institution has branches in two or more states of a multi-state MSA, group the assessment areas in that MSA.
3. Summarize conclusions about the institution's performance in each MSA and the
   nonmetropolitan portion of each state in which an assessment area was examined using these procedures. If two or more assessment areas in an MSA or in the nonmetropolitan portion of a state were examined using these procedures, determine the relative significance of the institution's performance in each assessment area by considering:
   a. The significance of the institution's activities in each compared to the institution's overall activities; b. The community development opportunities in each;

OCC, FRB, FDIC February 2006
c. The significance of the institution's activities for each, particularly in light of the
number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
4. For assessment areas in MSAs and nonmetropolitan areas that were not examined,
consider facts and data related to the institution's community development lending, investment, and service activities to ensure that performance in those areas is not inconsistent with the conclusions based on the assessment areas examined.
5. Assign a preliminary rating for an institution with operations in one state only using the
Community Development Ratings Matrix. For an institution with operations in more than one state or multi-state MSA, assign a preliminary rating for each state, using the Community Development Ratings Matrix. To determine the relative significance of each MSA and nonmetropolitan area to the institution's overall rating (institutions operating in only one state) or state-wide or multi-state MSA rating (institutions operating in more that one state), consider:
a. The significance of the institution's activities in each compared to the institution's overall activities; b. The community development opportunities in each;
c. The significance of the institution's activities for each, particularly in light of the
number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
6. For institutions with operations in more than one state or multi-state MSA, assign a
preliminary rating for the institution as a whole. To determine the relative significance of each state or multi-state MSA consider:
a. The significance of the institution's activities in each compared to the institution's overall activities; b. The community development opportunities in each;
c. The significance of the institution's activities for each, particularly in light of the
number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
7. If the institution is adequately meeting the community development needs of each of its
assessment area(s), consider those community development activities, if any, that benefit areas outside of the assessment area(s) or a broader statewide or regional area that

OCC, FRB, FDIC February 2006 includes the assessment area(s). Determine whether those activities enhance the preliminary rating. If so, adjust the rating(s) accordingly.
8. Consider an institution's past performance if the prior rating was "Needs to Improve." If
the poor performance has continued, an institution could be considered for a "Substantial Noncompliance" rating.
9. Review the results of the most recent compliance examination and determine whether
evidence of discrimination or other illegal credit practices that violate an applicable law, rule, or regulation should lower the institution's preliminary composite rating or the preliminary CRA rating for a state or multistate MSA. (Footnote 2. “Evidence of discriminatory or other illegal credit practices” includes, but is not limited to: (a) Discrimination against applicants on a prohibited basis in violation, for example, of the Equal Credit Opportunity Act or the Fair Housing Act; (b) Violations of the Home Ownership and Equity Protection Act; (c) Violations of section 5 of the Federal Trade Commission Act; (d) Violations of section 8 of the Real Estate Settlement Procedures Act; and (e) Violations of the Truth in Lending Act regarding a consumer’s right of rescission.) If evidence of discrimination or other illegal credit practices by the institution in any geography, or in any assessment area by any affiliate whose loans have been considered as part of the bank’s lending performance, was found, consider the following:
. a. The nature, extent, and strength of the evidence of the practices; b. The policies and procedures that the institution (or affiliate, as applicable) has in place to prevent the practices;
c. Any corrective action the institution (or affiliate, as applicable) has taken, or has
committed to take, including voluntary corrective action resulting from self￾assessment; and d. Any other relevant information.
10. Assign a final composite rating to the institution, considering the preliminary rating and
any evidence of discriminatory or other illegal credit practices, and discuss conclusions with management.
11. Write comments for the public evaluation and examination report.
12. Prepare recommendations for supervisory strategy and matters that require attention for
follow-up activities.
Public File Checklist

1. There is no need to review each branch or each complete public file during every
   examination. In determining the extent to which the institution’s public files should be reviewed, consider the institution's record of compliance with the public file requirements

OCC, FRB, FDIC February 2006 in previous examinations, its branching structure and changes to it since its last examination, complaints about the institution's compliance with the public file requirements, and any other relevant information.
2. In any review of the public file undertaken, determine whether branches display an
accurate public notice in their lobbies, a complete public file is available in the institution's main office and at least one branch in each state, and the public file(s) in the main office and in each state contain:
a. All written comments from the public relating to the institution's CRA performance and any responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution); b. The institution's most recent CRA Performance Evaluation;
c. A map of each assessment area showing its boundaries and, on the map or in a
separate list, the geographies contained within the assessment area; d. A list of the institution's branches, branches opened and closed during the current and each of the prior two calendar years, their street addresses and geographies; e. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution's branches), including a description of any material differences in the availability or cost of services between those locations; f. The institution's CRA Disclosure Statement(s) for the prior two calendar years; g. A quarterly report of the institution's efforts to improve its record if it received a less than satisfactory rating during its most recent CRA examination; h. HMDA Disclosure Statements for the prior two calendar years and those of each non￾depository affiliate the institution has elected to include in assessment of its CRA record, if applicable; and
i. If applicable, the number and dollar amount of consumer loans made to the four
income categories of borrowers and geographies (low-, moderate-, middle-, and upper-income), located inside and outside of the assessment area(s).
3. In any branch review undertaken, determine whether the branch provides the most recent
public evaluation, and a list of services generally available at its branches, and a description of any material differences in the availability or cost of services at the branch (or a list of services available at the branch).

OCC, FRB, FDIC February 2006
Community Development Ratings Matrix
Community Development
Test Characteristic column heading
OUTSTANDING column heading SATISFACTORYcolumn headinNEED g S TO IMPROVE column heading SUBSTANTIAL NONCOMPLIANCE column heading Investment, loan, and service activity OUTSTANDING Investment, loan, and service activity The institution has a high level of community development loans, community development services, or qualified investments, particularly investments that are not routinely provided by private investors. SATISFACTORY Investment, loan, and service activity The institution has an adequate level of community development loans, community development services, or qualified investments, particularly investments that are not routinely provided by private investors. NEEDS TO IMPROVE Investment, loan, and service activity The institution has a poor level of community development loans, community development services, or qualified investments, particularly investments that are not routinely provided by private investors SUBSTANTIAL NONCOMPLIANCE Investment, loan, and service activity The institution has few, if any, community development loans, community development services, or qualified investments, particularly investments that are not routinely provided by Investment, loan, and service private investors. initiatives OUTSTANDING Investment, loan, and service initiatives The institution extensively uses innovative or complex qualified investments, community development loans, or community development services. SATISFACTORY Investment, loan, and service initiatives The institution occasionally uses innovative or complex qualified investments, community development loans, or community development services. NEEDS TO IMPROVE Investment, loan, and service initiatives The institution rarely uses innovative or complex qualified investments, community development loans, or community development services. SUBSTANTIAL NONCOMPLIANCE Investment, loan, and service initiatives The institution does not use innovative or complex qualified investments, community development loans, or community development services. Responsiveness to community development needs OUTSTANDING Responsiveness to community development needs The institution exhibits excellent responsiveness to credit and community economic development needs in its assessment area(s). SATISFACTORY Responsiveness to community development needs The institution exhibits adequate responsiveness to credit and community economic development needs in its assessment area(s). NEEDS TO IMPROVE Responsiveness to community development needs The institution exhibits poor responsiveness to credit and community economic needs in its assessment area(s). SUBSTANTIAL NONCOMPLIANCE Responsiveness to community development needs The institution exhibits very poor responsiveness to credit and community economic development needs in its assessment area(s).

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OCC, FRB, FDIC February 2006
COMMUNITY REINVESTMENT ACT
EXAMINATION PROCEDURES FOR INSTITUTIONS WITH STRATEGIC PLANS Examination Scope

1. For institutions with more than one assessment area, identify assessment areas for full
   scope review. To select one or more assessment areas for full scope review, analyze prior performance evaluations, available community contact materials, reported lending data and demographic data on each assessment area and consider factors such as:
   a. The level of the institution's lending, investment and service 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 (Footnote 1. The Board of Governors of the Federal Reserve System, The Federal Deposit Insurance Corporation, and The Office of the Comptroller of the Currency) based on (a) rates of poverty, unemployment, and population loss or (b) population size, density, and dispersion (Footnote 2. A list of distressed or underserved nonmetropolitan middle-income geographies is available on the FFIEC web site at www.ffiec.gov. ); b. The number of other institutions in the different assessment areas and the importance of the institution under examination in meeting credit needs in the different assessment areas, particularly in areas with a limited number of financial service providers;
   c. The existence of apparent anomalies in the reported lending data for any particular
   assessment area(s); d. The time since the assessment area(s) most recently received a full scope examination; e. Performance that falls short of plan goals based on a review of available data; f. The institution's prior CRA performance in the different assessment areas; and g. Comments from the public regarding the institution's CRA performance.

OCC, FRB, FDIC February 2006
2. For interstate institutions, a rating must be assigned for each state where the institution
has a branch and in every multistate MSA where the institution has branches in two or more of the states that comprise that multistate MSA. Select one or more assessment areas in each state for examination using these procedures. Performance Context
4. Review the institution's public file for any comments received by the institution or the
agency since the last CRA performance evaluation that assists in evaluating the institution's record of meeting plan goals.
5. Consider any information that the institution provides on its record of meeting plan goals.
6. Contact local community, governmental or economic development representatives to
update or supplement information about the institution's record of meeting plan goals.
7. As necessary, consider any information the institution or others may provide on local
community and economic conditions that may affect the institution's ability to meet plan goals or otherwise assist in the evaluation of the institution. Performance Criteria

1. Review the following:
   a. The approved plan and approved amendments; b. The agency's approval process files; and
   c. Written comments from the public that the institution or the agency received since the
   plan became effective.
2. Determine whether the institution achieved its performance goals for each assessment
   area examined. a. Review the plan's measurable annual goals for each performance category and assessment area(s) to be reviewed. b. Obtain information and data about the institution's actual performance for the period that has elapsed since the previous examination.

OCC, FRB, FDIC February 2006
c. Compare the plan goals for each assessment area reviewed to the institution's actual
performance since its last examination in each assessment area reviewed to determine if all of the plan's goals have been met.
3. If any goals were not met, form a conclusion as to whether the plan goals were
"substantially met." In doing so, consider the number of unmet goals, the degree to which the goals were not met, the importance of those goals to the plan as a whole, and the reasons why the goals were not met (e.g., economic factors beyond the institution's control).
4. Discuss preliminary findings with management.
5. Summarize conclusions about the institution's performance.
Ratings
These instructions assume that the strategic plan covers all of the institution's assessment areas. If not, the analysis of performance for the assessment area(s) covered by the strategic plan must be combined with the analyses for assessment areas that were subject to other assessment method(s) in order to assign a rating.

1. Group the analyses of the assessment areas examined by MSA (Footnote 3. The reference to MSA may also reference metropolitan division (MD).
   ) and nonmetropolitan areas within each state where the institution has branches. If an institution has branches in two or more states of a multi-state MSA, group the assessment areas that are in that MSA.
2. If the institution has substantially met its plan goals for a satisfactory rating or, if
   applicable, an outstanding rating, in all assessment areas reviewed, summarize conclusions about the institution's performance in each MSA and the nonmetropolitan area of each state in which an assessment area was examined using these procedures. Assign the appropriate preliminary rating for the institution and, as applicable, each state or multistate MSA and proceed to Step 6, below.
3. If the institution did not substantially meet its plan goals in each assessment area, check
   to determine if the institution elected in its plan to be evaluated under an alternate assessment method. a. If the institution did not elect in the plan to be evaluated under an alternate assessment method, assign a "Needs to Improve" or "Substantial Noncompliance" rating to those assessment areas in which plan goals were not substantially met, depending on the number of goals missed, the extent to which they were missed, and their importance to the plan overall.

OCC, FRB, FDIC February 2006 b. If the institution elected in its plan to be evaluated under an alternate assessment method, perform the appropriate procedures to evaluate and rate the institution's performance in those assessment areas in which the institution did not meet plan goals.
4. For institutions operating in multiple assessment areas, determine the relative importance
of the assessment areas reviewed in forming conclusions for each MSA and the nonmetropolitan area within each state and for any multistate MSA where the institution has branches in two or more states. In making that determination, consider:
a. The significance of the institution's activities in each compared to the institution's overall activities; b. The lending, service, and investment opportunities in each;
c. The significance of the institution's loans, qualified investments, and lending-related
services, as applicable, for each, particularly in light of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
5. For an institution operating in multiple MSAs or nonmetropolitan areas in one or more
states or multi-state MSAs, assign a preliminary rating for each state and multi-state MSA. To determine the relative significance of each MSA and nonmetropolitan area to the rating in a state, consider:
a. The significance of the institution's activities in each compared to the institution's overall activities; b. The lending, service, and investment opportunities in each;
c. The significance of the institution's loans, qualified investments, and lending-related
services, as applicable, for each, particularly in light of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
6. For institutions with operations in more than one state, assign a preliminary overall
rating. In determining the relative significance of the institution's performance in each state or multistate MSA to its overall rating consider:
a. The significance of the institution's activities in each compared to the institution's overall activities; b. The lending, service, and investment opportunities in each;

OCC, FRB, FDIC February 2006
c. The significance of the institution's loans, qualified investments, and lending-related
services, as applicable, for each, particularly in light of the number of other institutions and the extent of their activities in each; and d. Demographic and economic conditions in each.
7. Review the results of the most recent compliance examination and determine whether
evidence of discriminatory or other illegal credit practices that violate an applicable law, rule, or regulation should lower the institution’s overall CRA rating or, if applicable, its CRA rating in any state or multi-state MSA.4 If evidence of discrimination or other illegal credit practices in any geography by the institution, or in any assessment area by any affiliate whose loans were considered as part of the institution’s lending performance, was found, consider:
a. The nature, extent, and strength of the evidence of the practices; b. The policies and procedures that the institution (or affiliate, as applicable) has in place to prevent the practices;
c. Any corrective action the institution (or affiliate, as applicable) has taken, or has
committed to take, including voluntary corrective action resulting from self￾assessment; and d. Any other relevant information.
8. Discuss conclusions with management and assign a final rating to the institution and state
or multi-state MSA ratings, as applicable, considering the preliminary rating and any evidence of discrimination and other illegal credit practices.
9. Write comments for the public evaluation and the examination report.
Public File Checklist

1. There is no need to review each branch or each complete public file during every
   examination. In determining the extent to which the institution's public files should be reviewed, consider the institution's record of compliance with the public file requirements in previous examinations, its branching structure and changes to it since its last examination, complaints about the institution's compliance with the public file requirements, and any other relevant information. 4 “Evidence of discriminatory or other illegal credit practices” includes, but is not limited to: (a) Discrimination against applicants on a prohibited basis in violation, for example, of the Equal Credit Opportunity Act or the Fair Housing Act; (b) Violations of the Home Ownership and Equity Protection Act; (c) Violations of section 5 of the Federal Trade Commission Act; (d) Violations of section 8 of the Real Estate Settlement Procedures Act; and (e) Violations of the Truth in Lending Act regarding a consumer’s right of rescission.

OCC, FRB, FDIC February 2006
2. In any review of the public file undertaken, determine whether branches display an
accurate public notice in their lobbies, a complete public file is available in the institution's main office and at least one branch in each state, and the public file available in the main office and in each state contains:
a. A copy of the approved strategic plan; b. All written comments from the public relating to the institution's CRA performance and any responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution);
c. The institution's most recent CRA Performance Evaluation;
d. A map of each assessment area showing its boundaries and, on the map or in a separate list, the geographies contained within the assessment area; e. A list of the institution's branches, branches opened and closed during the current and each of the prior two calendar years, their street addresses and geographies; f. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution's branches), including a description of any material differences in the availability or cost of services between those locations; g. The institution's CRA Disclosure Statement(s) for the prior two calendar years; h. A quarterly report of the institution's efforts to improve its record if it received a less than satisfactory rating during its most recent CRA examination;
i. HMDA Disclosure Statements for the prior two calendar years for the institution and
for each non-depository affiliate the institution has elected to include in assessment of its CRA record, if applicable; j . The number and dollar amount of consumer loans, for large banks, if applicable; and k. The loan-to-deposit ratio, for small institutions.
3. In any branch review undertaken, determine whether the branch provides the most recent
public evaluation and a list of services generally available at its branches and a description of any material differences in the availability or cost of services at the branch (or a list of services available at the branch).

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INSTRUCTIONS FOR WRITING PUBLIC EVALUATIONS
The format of all of the public evaluation templates follows the provisions of amendments to the Community Reinvestment Act that require the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation (Agencies) to:
1. Rate the institution's overall performance in meeting the credit needs of its
community;
2. For an interstate institution, rate each state in which the bank has branches
or multistate metropolitan statistical area (MSA) in which the institution has branches in more than one state; and
3. Separately present the conclusions for the performance test(s) or criteria
considered in arriving at the rating as well as the facts and data supporting those conclusions for each MSA in which the institution has branches. The contents of the public evaluation will vary depending on the nature of the institution examined and the examination method used. Public evaluation templates for small institutions, intermediate small institutions, large institutions, wholesale and limited purpose institutions, and institutions operating under approved strategic plans have been prepared by the Agencies. These templates provide guidance regarding the structure and contents of the public evaluations. Except for the intrastate public evaluations for small institutions and intermediate small institutions, the templates are structured to meet the requirements that the CRA imposes on public evaluations for interstate institutions. The samples can easily be adjusted to suit the requirements for institutions with branches in only one state. Evaluations for Institutions with Branches in Only One State. Regardless of the examination method used, the public evaluation for institutions with branches in only one state must contain the institution's overall CRA rating and the conclusions for the performance test(s) or criteria upon which the rating is based. No state or multistate MSA rating is needed for intrastate institutions. Also, there is no requirement to rate an institution’s performance in each assessment area. Rather, the public evaluation must present conclusions about the institution’s performance in the assessment area(s) subject to the following guidance:
1. If the institution has branches in more than one MSA, the public evaluation must
present the conclusions for each performance test(s) or criterion, along with supporting facts and data, separately for each MSA. Revision history: On June 2, 2026: Reputation risk is no longer a component of federal examination programs. See, e.g., Federal Reserve press release, OCC bulletin, and FDIC Financial Institution Letter.

2. If the institution has defined more than one assessment area within a
nonmetropolitan statewide area, separate discussion of CRA performance within a nonmetropolitan statewide area for intrastate institutions that have branches in metropolitan and nonmetropolitan areas is optional because the performance in the nonmetropolitan areas has been discussed in the overall evaluation of the institution. Examiners may wish to discuss in greater detail, however, the assessment areas within the nonmetropolitan statewide areas that were reviewed using the examination procedures for (1) intrastate institutions with branches in MSAs or nonmetropolitan areas or (2) intrastate institutions with branches only in nonmetropolitan areas. More detailed discussions of each assessment area examined should follow the appropriate MSA and nonmetropolitan area presentation. Evaluations for Interstate Institutions In addition to the institution's overall CRA rating, public evaluations for interstate institutions must contain ratings for each state in which the institution has branches and multistate MSA in which the institution has branches in more than one state of the multistate MSA. The public evaluation for interstate institutions is, therefore, organized to present the institution's overall rating first, followed by the multistate MSA rating(s), and then the state rating(s). The discussion of the overall institution, multistate MSA, and state ratings must include the conclusions for the performance test(s) or criteria upon which the rating(s) is based. An institution’s performance in each assessment area is not rated. Rather, the public evaluation must present the conclusions about the institution’s performance in the assessment area(s) subject to the following guidance:
1. Multistate MSA presentations should be followed by discussions of the
performance within assessment area(s) within the multistate MSA.
2. Separate MSA presentations for each MSA where the institution has branches
should follow the appropriate state presentation. A discussion of an institution’s CRA performance within a nonmetropolitan area statewide area is required for institutions with branches in two or more states. Include a discussion about how the examination of the institution was performed, including a list of the individual branches examined. Again, more detailed assessment area discussions follow the applicable MSA and nonmetropolitan area discussions. Conclusions based on Performance Tests

The CRA requires the Agencies to present conclusions for each of the performance test(s) or criteria considered in arriving at a rating. The performance evaluations should reflect the conclusions reached under these performance tests.

• For large institutions, the public evaluation must indicate the conclusions
  reached under the lending, investment, and service tests.
• For intermediate small institutions, the public evaluation must indicate the
  conclusions under the lending and community development tests.
• For small institutions, the streamlined assessment method for small
  institutions focuses on lending performance. However, to the extent that investment and service performance were considered in rating a small institution "Outstanding," the conclusions for each must be in the public evaluation.
• For wholesale and limited purpose institutions, conclusions for the
  community development test must be discussed in the performance evaluation.
• Finally, for institutions that operate under an approved strategic plan, the
  performance evaluation for those institutions must contain conclusions for the tests used in the examination. Hybrid Performance Evaluations When an institution is examined under more than one examination method, the examiner should develop a hybrid performance evaluation. The evaluation should state the examination methods used in the General Information section. In addition, the discussion of the scope should indicate the examination method that was used in each assessment area examined. Finally, discussions of the analysis used under each assessment area presentation should note the applicable examination method. Charts, Tables and Appendices Charts and tables should be used throughout the public evaluation to facilitate discussion of the institution's performance. In addition, the inclusion of one or more appendices may facilitate the presentation of information in the public evaluation. For example,
  Appendix A is a chart describing the scope of the examination and should be used for
  institutions with numerous assessment areas. Appendix B should be used to summarize the state ratings for interstate institutions. Other charts and tables may be used to assist the reader and amplify the discussion of an institution's performance.

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FFIEC - Community Contact Form
Examiners should summarize each interview they conduct on the Community Contact Form. The purpose of this form is to provide a consistent means by which financial institution regulators can share information obtained through interviews for a particular community. The individual conducting the interview should inform the interviewees that this information will be shared with other regulatory agencies.

1. Regulatory Agency:

2. Date of contact:

3. Interviewee information:
   Name:
   Organization represented:
   Type / Organization Category:
   Address:
   Title:
   City:
   Interviewee's Telephone:
   Add Area Served:
   State:
   Served State(s): Served MSA(s): Served Counties:

4. Was this the first contact with this organization (in connection with a current examination) or a
   follow-up contact?
   First ___ Follow-up ___

5. Was the interview conducted in conjunction with an examination? If yes, list financial
   institutions.
   Institution Name Cert Charter Docket RSSD

6. Summarize the organization's purposes, functions and sources of funding. Include the organization's
   impact if applicable (for example: number of low-income clients served, number of units built, etc.)

7. Political or geographic boundaries of area focused on during this specific contact:

8. Interview Summary:
   a) Community Profile
   Current economic conditions; current demographic characteristics; general banking and credit needs; other (e.g. Identifying names of low or moderate income neighborhoods). b) Opportunities for participation by local financial institutions Community development, other credit-related projects, or financing programs; level of opportunity for bank involvement c) Performance of local financial institutions

Perceptions or experience regarding the degree of involvement of the local financial institution industry and of the specific financial institution (if obtained) in the community
9. Person in charge of
examination:
Interviewer:
Reviewed by: