SAMPLE STRATEGIC PLAN INSTITUTION EVALUATION\*

**PUBLIC DISCLOSURE**

(Date of Evaluation)

**COMMUNITY REINVESTMENT ACT**

**PERFORMANCE EVALUATION**

Name of Depository Institution

Institution\'s Identification Number

Address of Institution

Name of Supervisory Agency

Address of Supervisory Agency

NOTE: This document is an evaluation of this institution\'s record of
meeting the credit needs of its entire community, including low- and
moderate-income neighborhoods, consistent with safe and sound operation
of the institution. This evaluation is not, nor should it be construed
as, an assessment of the financial condition of this institution. The
rating assigned to this institution does not represent an analysis,
conclusion or opinion of the federal financial supervisory agency
concerning the safety and soundness of this financial institution.

\* This table of contents is a sample for a large institution, and
should be adjusted, as appropriate, to reflect the requirements of
Section 807 of the CRA (12 USC 2906), and each institution's operations.

**TABLE OF CONTENTS**

I. Institution Rating

> a\. Overall Rating. . . . . . . . . . . . . . . . . . . . . . . . . .
> . . . . . . . . . . . . . . . . . . . . . 1
>
> b\. Discussion. . . . . . . . . . . . . . . . . . . . . . . . . . . .
> . . . . . . . . . . . . . . . . . . . . . . 1

II\. Multistate Metropolitan Area Rating. . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . 3

> a\. Discussion of assessment areas within multistate metropolitan area

examined using a full-scope review

> b\. Facts and data for multistate metropolitan area assessment areas

examined using a limited-scope review

III\. State Rating. . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . 4

> a\. Metropolitan Area Analysis. . . . . . . . . . . . . . . . . . . .
> . . . . . . . . . . . . . . . . 5
>
> i\. Conclusions
>
> ii\. Discussion of assessment areas within metropolitan area examined

using a full-scope review

> iii\. Facts and data for metropolitan area examined using a
> limited-scope review
>
> b\. Nonmetropolitan Statewide Area Analysis. . . . . . . . . . . . . .
> . . . . . . . . . . . 6
>
> i\. Conclusions
>
> ii\. Discussions of nonmetropolitan area assessment areas examined

using a full-scope review

> iii\. Facts and data for nonmetropolitan area assessment areas

examined using a limited-scope review

IV\. Appendix

> a\. Scope of Examination Table . . . . . . . . . . . . . . . . . . . .
> . .. . . . . . . . . . . . . 9
>
> b\. Summary of State and Multistate Metropolitan Area Ratings . . . .
> . . . .. 11

**INSTITUTION**

***INSTITUTION\'S CRA RATING:*** **This institution is rated
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_.**

Summarize the major factors supporting the institution\'s rating. When
evidence of discriminatory or other illegal credit practices
inconsistent with helping to meet community credit needs has been
identified in the supervisory process, the conclusion must include a
statement if the rating was influenced by this evidence. The conclusion
should not mention any technical violations.

**SCOPE OF EXAMINATION**

Write a short description of the scope of the examination. Discuss how
CRA activities were reviewed (using full-scope or limited-scope review).
Include a description of loan samples used in your analysis. When
appropriate, you may also refer the reader to a chart similar to that
included in Appendix A.

**[CONCLUSIONS]{.underline}**

Summarize the facts, data, and analyses that were used to determine the
overall rating, based on the institution\'s plan goals and actual
performance under the plan. The discussion should be organized broadly
around the lending, investment and service goals, as applicable. If the
institution has not substantially met its goals, discuss the effect, if
any, changed circumstances may have on the rating. Charts and tables
should be used whenever possible to summarize and effectively present
the most critical or informative data used by the examiner in analyzing
the institution\'s performance and reaching conclusions.

**FAIR LENDING OR OTHER ILLEGAL CREDIT PRACTICES REVIEW**

Write a paragraph about the institution's record of complying with laws
relating to discrimination or other illegal credit practices
inconsistent with helping to meet community credit needs using the
following guidelines:

> If no substantive violations were found, state that no evidence of
> discriminatory or other illegal credit practices inconsistent with
> helping to meet community credit needs was identified. Even if
> discrimination has not been found, comments related to the
> institution's fair lending policies, procedures, training programs and
> internal assessment efforts may still be appropriate.
>
> When substantive violations involving discriminatory or other illegal
> credit practices inconsistent with helping to meet community credit
> needs have been identified, state that substantive violations were
> found, whether they caused the CRA rating to be adjusted downward, and
> why the rating was or was not adjusted. Identify the law(s) and
> regulation(s) violated, the extent of the violation(s) (e.g.,
> widespread, or limited to a particular office, division, subsidiary,
> or affiliate) and characterize management's responsiveness in acting
> upon the issue(s). Discuss whether the institution has policies,
> procedures, training programs, internal assessment efforts, or other
> practices in place to prevent discriminatory or other illegal credit
> practices. State whether management has taken, or has committed to
> take, corrective action particularly with respect to voluntary
> corrective action resulting from self-assessment(s).

**MULTISTATE METROPOLITAN AREA**

***CRA RATING FOR (Name of Multistate Metropolitan Area and
States)[\_\_\_\_\_\_\_\_\_ ]{.underline}***

*\[Complete for each multistate metropolitan area where an institution
has branches in two or more states within the multistate metropolitan
area.\]*

Summarize the major factors supporting the institution\'s multistate
metropolitan area rating. When evidence of discriminatory or other
illegal credit practices inconsistent with helping to meet community
credit needs has been identified in the supervisory process, the
conclusion must include a statement if the rating was influenced by this
evidence. The conclusion should not mention any technical violations.

**SCOPE OF EXAMINATION**

Write a short description of the scope of the examination within the
multistate metropolitan area.

Discuss how CRA activities in the multistate metropolitan area were
reviewed (using full-scope or limited-scope review). When appropriate,
you may also refer the reader to a chart similar to that included in
Appendix A.

**DESCRIPTION OF INSTITUTION'S OPERATIONS IN *(Name of Multistate
Metropolitan Area)***

Describe the institution\'s operations within the multistate
metropolitan area, including a description of each of the assessment
areas that it serves within the multistate metropolitan area. Indicate
how many of these assessment areas were reviewed using a full-scope
review.

**CONCLUSIONS WITH RESPECT TO PERFORMANCE IN *(Name of Multistate
Metropolitan Area and States****)*

Discuss the institution\'s CRA performance within the multistate
metropolitan area. The facts, data, and analyses that were used to form
a conclusion about the rating, as well as the institution\'s record in
assessment areas in the multistate metropolitan area that were examined
using a limited-scope review, should be reflected in the narrative. The
discussion should be based on the institution\'s plan goals and actual
performance under the plan, and organized around the lending, investment
and service goals, as applicable. If the institution has not
substantially met its goals, discuss the effect, if any, changed
circumstances may have on the rating. Charts and tables should be used
whenever possible to summarize and effectively present the most critical
or informative data used by the examiner in analyzing the institution\'s
performance and reaching conclusions.

If the institution\'s assessment area(s) are smaller than the boundaries
of the multistate metropolitan area, a discussion of the assessment
areas examined should be included. Refer to the assessment area
discussion, below.

**STATE**

***CRA RATING FOR (Name of State):\_\_\_\_\_\_\_\_\_\_\_\_***

*\[If the institution has branches in more than one state, complete this
section for each state. Otherwise, complete the metropolitan area and
nonmetropolitan statewide area presentations only, as applicable.\]*

Summarize the major factors supporting the institution\'s state rating.
When evidence of discriminatory or other illegal credit practices
inconsistent with helping to meet community credit needs has been
identified in the supervisory process, the conclusion must include a
statement if the rating was influenced by this evidence. The conclusion
should not mention any technical violations.

**SCOPE OF EXAMINATION**

Write a short description of the scope of the examination within the
state. Discuss how CRA activities in the state were reviewed (using
full-scope or limited-scope review). When appropriate, you may also
refer the reader to a chart similar to that included in Appendix A.

**DESCRIPTION OF INSTITUTION'S OPERATIONS IN *(Name of State)***

Describe the institution\'s operations within the state and the
assessment area(s) that it serves. Information that may be important
includes: total statewide assets; asset/loan portfolio mix; primary
business focus; branching network; any merger or acquisition activity;
and a brief description of the assessment areas within the state.

**CONCLUSIONS WITH RESPECT TO PERFORMANCE IN *(Name of State)***

Discuss the institution\'s CRA performance within the state. The facts,
data, and analyses that were used to form a conclusion about the rating,
based on the institution\'s plan goals and actual performance under the
plan, should be reflected in the narrative. The discussion should be
organized around the lending, investment and service goals, as
applicable. If the institution has not substantially met its goals,
discuss the effect, if any, changed circumstances may have on the
rating. Charts and tables should be used whenever possible to summarize
and effectively present the most critical or informative data used by
the examiner in analyzing the institution\'s performance and reaching
conclusions.

**METROPOLITAN AREAS**

**CONCLUSIONS WITH RESPECT TO PERFORMANCE IN *(Name of Metropolitan Area
and State)***

Discuss the institution\'s CRA performance within the metropolitan area.
The facts, data, and analyses that were used to form a conclusion, as
well as the institution\'s record in assessment areas in the
metropolitan areas that were examined using a limited-scope review,
should be reflected in the performance evaluation. The discussion should
be based on the institution\'s plan goals and actual performance under
the plan, and organized around the lending, investment and service
goals, as applicable. If the institution has not substantially met its
goals, discuss the effect, if any, changed circumstances may have on the
rating. Charts and tables should be used whenever possible to summarize
and effectively present the most critical or informative data used by
the examiner in analyzing the institution\'s performance and reaching
conclusions.

If the institution's assessment area(s) are smaller than the boundaries
of the metropolitan area, a discussion of the assessment areas examined
should be included. Refer to the assessment area discussion, below.

**NONMETROPOLITAN STATEWIDE AREAS**

**CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN *(Name of
Nonmetropolitan Statewide Area and State)***

Discuss the institution\'s CRA performance within the nonmetropolitan
statewide area. The facts, data, and analyses that were used to form a
conclusion, as well as the institution\'s record in assessment areas in
the nonmetropolitan statewide area that were examined using a
limited-scope review, should be reflected in the performance evaluation.
The discussion should be based on the institution\'s plan goals and
actual performance under the plan, and organized around the lending,
investment and service goals, as applicable. If the institution has not
substantially met its goals, discuss the effect, if any, changed
circumstances may have on the rating. Charts and tables should be used
whenever possible to summarize and effectively present the most critical
or informative data used by the examiner in analyzing the institution\'s
performance and reaching conclusions.

A discussion of the assessment areas examined using a full-scope review
should be included. Refer to the assessment area discussion, below.

**ASSESSMENT AREA**

*(for each assessment area examined using a full-scope review)*

Charts or tables may be useful in depicting information throughout the
assessment area presentation.

**DISCUSSION OF PERFORMANCE IN (ASSESSMENT AREA NAME):**

**\[Repeat for [each]{.underline}** assessment area.\]

+------+-----------------------------+---------------------------------+
| **S  |                             |                                 |
| TRAT |                             |                                 |
| EGIC |                             |                                 |
| PLAN |                             |                                 |
| G    |                             |                                 |
| OALS |                             |                                 |
| AND  |                             |                                 |
| AC   |                             |                                 |
| TUAL |                             |                                 |
| P    |                             |                                 |
| ERFO |                             |                                 |
| RMAN |                             |                                 |
| CE** |                             |                                 |
|      |                             |                                 |
| *    |                             |                                 |
| *FOR |                             |                                 |
| EDEN |                             |                                 |
| PRA  |                             |                                 |
| IRIE |                             |                                 |
| AND  |                             |                                 |
| D    |                             |                                 |
| AVIS |                             |                                 |
| COUN |                             |                                 |
| TIES |                             |                                 |
| IN   |                             |                                 |
| MIN  |                             |                                 |
| NESO |                             |                                 |
| TA** |                             |                                 |
|      |                             |                                 |
| **TO |                             |                                 |
| OB   |                             |                                 |
| TAIN |                             |                                 |
| SATI |                             |                                 |
| SFAC |                             |                                 |
| TORY |                             |                                 |
| RATI |                             |                                 |
| NG** |                             |                                 |
+------+-----------------------------+---------------------------------+
| **   | **Strategic Plan Goal**     | **Actual Performance**          |
| Samp |                             |                                 |
| le** |                             |                                 |
+------+-----------------------------+---------------------------------+
|      | **1 . \$1.5 million in      | **1. \$1.32 million in loans**  |
|      | small farm loans**          |                                 |
+------+-----------------------------+---------------------------------+
|      | **2. \$2.0 million in loans | **2. \$3.7 million in loans.**  |
|      | to small businesses**       |                                 |
+------+-----------------------------+---------------------------------+
|      | **3. \$.5 million in loans  | **3. \$.39 million in loans.**  |
|      | to start-up businesses**    |                                 |
+------+-----------------------------+---------------------------------+
|      | **4. Provide                | **4. Construction line of       |
|      | construction/permanent      | credit approved for \$960,000.  |
|      | financing for 24-unit       | \$100,000 disbursed to date.**  |
|      | elderly low-income housing  |                                 |
|      | project**                   |                                 |
+------+-----------------------------+---------------------------------+
|      |                             |                                 |
+------+-----------------------------+---------------------------------+

Summarize the facts, data, and analyses that were used to form a
conclusion on the institution\'s performance in the assessment area.
This should compare and contrast the institution\'s plan goals for the
assessment area and actual performance under the plan. Explain variances
between the plan and actual results. If the institution has not
substantially met its goals, discuss the performance context and its
impact on the conclusion. The discussion should be organized around the
lending, investment and service goals, as applicable. Use the chart
above to supplement the written summary, and note whether the analysis
was conducted using a full-scope review.

**ASSESSMENT AREA**

*(for those assessment areas that were examined using a limited-scope
review. Multiple assessment areas within the same multistate
metropolitan area, metropolitan area, or nonmetropolitan statewide area
and examined using a limited-scope review, may be combined into one
presentation.)*

Charts or tables may be useful in depicting information throughout the
presentation.

**DISCUSSION OF PERFORMANCE IN *(Name of Assessment Area)***

Summarize the facts and data that were reviewed and indicate whether the
institution\'s performance in the area reviewed is consistent with the
institution\'s record in the multistate metropolitan area, metropolitan
area, or nonmetropolitan statewide area.

APPENDIX A

**SCOPE OF EXAMINATION TABLE**

Charts that illustrate the scope of the examination may be useful for
large institutions with multiple assessment areas or institution\'s that
use data from their affiliates. Charts, such as the ones below, may be
used as a supplement to the discussion of the scope or in lieu thereof.

+--------------------+----------+---------+---------------------------+
| **SCOPE OF         |          |         |                           |
| EXAMINATION**      |          |         |                           |
| \[*SAMPLE*\]       |          |         |                           |
|                    |          |         |                           |
| \[Note: Example    |          |         |                           |
| provided for       |          |         |                           |
| clarity\]          |          |         |                           |
+--------------------+----------+---------+---------------------------+
|                    |          |         |                           |
+--------------------+----------+---------+---------------------------+
| **TIME PERIOD      | 1/1/95   |         |                           |
| REVIEWED**         | TO       |         |                           |
|                    | 6/30/96  |         |                           |
+--------------------+----------+---------+---------------------------+
|                    |          |         |                           |
+--------------------+----------+---------+---------------------------+
| **FINANCIAL        |          | **P     |                           |
| INSTITUTION**      |          | RODUCTS |                           |
|                    |          | REV     |                           |
| XYZ National Bank, |          | IEWED** |                           |
| Eden Prairie, MN   |          |         |                           |
|                    |          | Small   |                           |
|                    |          | B       |                           |
|                    |          | usiness |                           |
|                    |          |         |                           |
|                    |          | Small   |                           |
|                    |          | Farm    |                           |
+--------------------+----------+---------+---------------------------+
|                    |          |         |                           |
+--------------------+----------+---------+---------------------------+
| **FINANCIAL        | **A      | **P     |                           |
| INSTITUTION/**     | FFILIATE | RODUCTS |                           |
|                    | RELATI   | REV     |                           |
| **AFFILIATE**      | ONSHIP** | IEWED** |                           |
+--------------------+----------+---------+---------------------------+
| XYZ Bancorp, Blue  | Holding  | Inve    |                           |
| Earth, MN          | Company  | stments |                           |
+--------------------+----------+---------+---------------------------+
| XYZ Community      | Holding  | Inve    |                           |
| Development        | company  | stments |                           |
| Corporation, Blue  | su       |         |                           |
| Earth, MN          | bsidiary |         |                           |
+--------------------+----------+---------+---------------------------+
| XYZ Savings Bank,  | Thrift - | M       |                           |
| Blue Earth, MN     | Holding  | ortgage |                           |
|                    | company  | lending |                           |
|                    | su       |         |                           |
|                    | bsidiary |         |                           |
+--------------------+----------+---------+---------------------------+
| XYZ National Bank, | Holding  | Credit  |                           |
| Tampa, FL          | company  | Cards   |                           |
|                    | su       |         |                           |
|                    | bsidiary |         |                           |
+--------------------+----------+---------+---------------------------+
|                    |          |         |                           |
+--------------------+----------+---------+---------------------------+
| **LIST OF          |          |         |                           |
| ASSESSMENT AREAS   |          |         |                           |
| AND TYPE OF        |          |         |                           |
| EXAMINATION**      |          |         |                           |
+--------------------+----------+---------+---------------------------+
| **ASSESSMENT       | **TYPE   | **BRA   | **OTHER INFORMATION**     |
| AREA**             | OF       | NCHES** |                           |
|                    | EXAMI    |         |                           |
|                    | NATION** | **VI    |                           |
|                    |          | SITED** |                           |
+--------------------+----------+---------+---------------------------+
| MINNESOTA          | Fu       |         |                           |
|                    | ll-scope |         |                           |
| Davis County and   | review   |         |                           |
| Eden Prairie       |          |         |                           |
| County (contiguous |          |         |                           |
| counties)          |          |         |                           |
+--------------------+----------+---------+---------------------------+
| FLORIDA            | Limit    |         |                           |
|                    | ed-scope |         |                           |
| City of Tampa      | review   |         |                           |
+--------------------+----------+---------+---------------------------+
|                    |          |         |                           |
+--------------------+----------+---------+---------------------------+

APPENDIX B

**SUMMARY OF STATE AND MULTISTATE METROPOLITAN AREA RATINGS**

  ----------------------------------- -----------------------------------
  State or Multistate Metropolitan    State Rating
  area Name                           

                                      

                                      

                                      

                                      

                                      

                                      

                                      
  ----------------------------------- -----------------------------------