Office of Thrift Supervision’s Community 

Reinvestment Act Performance Evaluations

 OIG-02-026 December 21, 2001

Office of Inspector General

*******

The Department of the Treasury
Contents

OTS’ CRA Performance Evaluations (OIG-02-026) Page 1

Audit Report....................................................................................................... 2

Results in Brief.................................................................................................. 3

Background....................................................................................................... 5

Findings and Recommendations.......................................................................... 8

Finding 1 OTS Generally Meeting the Basic Legislative CRA Requirements ...... 8

Recommendations 1, 2 and 3........................................................................11

Finding 2 Unsupported or Questionable CRA Ratings .................................... 13

 Recommendations 4, 5, 6 and 7................................................................... 20

Finding 3 Examiner Assessment of Community Credit Needs Could 

 Be Enhanced ............................................................................................. 23

Recommendations 8 and 9........................................................................... 25

Finding 4 Clear Guidance Needed for Non-traditional Thrifts........................... 26

Recommendation 10.................................................................................... 28

Appendices

Appendix 1: Objectives, Scope, and Methodology......................................... 30

Appendix 2: Thrifts Sampled for OIG Review................................................ 32

Appendix 3: Management Comments ........................................................... 33

Appendix 4: Major Contributors to This Report.............................................. 43

Appendix 5: Report Distribution.................................................................... 44

Abbreviations

CRA Community Reinvestment Act

FFIEC Federal Financial Institution Examination Council

GAO U.S. General Accounting Office

LMI Low- and moderate-income

OIG Office of Inspector General

OTS Office of the Thrift Supervision

PE Performance Evaluation
OIG Audit

Report

The Department of the Treasury

Office of Inspector General

OTS’ CRA Performance Evaluations (OIG-02-026) Page 2

December 21, 2001

James E. Gilleran

Director

Office of the Thrift Supervision

The Community Reinvestment Act (CRA) of 1977 was enacted to 

encourage depository institutions to improve access to credit and 

deposit services and to combat the practice of “redlining” certain 

communities. Under the Act, federal banking regulators evaluate 

the record of each insured depository institution on its performance 

in helping to meet the credit needs of the community in which it 

operates, consistent with safe and sound banking practices. In 

particular, this includes assistance to low- and moderate-income 

(LMI) neighborhoods. The Office of the Thrift Supervision (OTS) is 

responsible for ensuring that the 1,000 or more thrift institutions 

that it regulates comply with CRA. 

The objective of our audit was to determine whether the 

Performance Evaluation (PE) reports prepared by OTS examiners 

provide an accurate measure of CRA performance of thrift 

institutions, henceforth referred to as thrifts in this report. We 

focused on factors affecting the CRA ratings mainly for large 

thrifts. 

We conducted our fieldwork at OTS headquarters in Washington, 

D.C. and three OTS regional offices. At the regional offices, we 

reviewed a total judgmental sample of 41 CRA examinations and 

PE’s, supporting workpapers, and other CRA related documents. 

The sampled thrifts had assets ranging from $54 million to $70 

billion. We interviewed responsible regional CRA officials and field 

examiners. In addition, we met with a small number of thrift 

managers and community groups to get their perspective on CRA. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 3

A detailed description of the objectives, scope and methodology is 

presented in Appendix 1. 

Results in Brief

We found that OTS generally is carrying out its responsibilities 

under the Act. Specifically, OTS is conducting CRA examinations 

to assess thrift performance in meeting the credit and deposit 

needs of communities, taking into account CRA ratings when 

reviewing certain applications, and ensuring that CRA PE reports 

are available to the general public. 

However, during our audit, we found that certain aspects of the 

CRA examination process could be improved. It was not clear in 

PE reports whether examiners addressed all of the regulatory 

criteria to rate each CRA component when summarizing 

conclusions about performance. We were also unable to form an 

opinion as to whether current law or regulation provides sufficient 

sanctions when thrifts have less than Satisfactory CRA ratings 

because the regulation lacks the specific evaluative criteria needed 

to do so. Regulations require OTS to take into account a thrift’s 

CRA record when acting on an application. The regulations, 

however, do not specify how a thrift’s CRA performance is to be 

taken into account or weighed in the application process. 

In terms of CRA ratings, we were unable to validate the 

appropriateness of the lending ratings for eight (20%) of the 41 

sampled PE’s because the PE’s lacked sufficient performance 

context information to explain the examiners’ rationale for the 

ratings. For the remaining 33 thrifts in our sample, the PE’s 

provided adequate information to support the assigned ratings. We 

were also unable to validate the appropriateness of the investment 

component ratings for 17 (41%) of 41 thrifts and we found 

apparent rating inconsistencies among thrifts. Regulations do not 

provide the necessary evaluative guidance for the investment 

component and PE’s did not always discuss performance context 

for investments. Without this information, we could not validate 

how the investment ratings were derived, determine their 

appropriateness, or reconcile apparent inconsistencies. We also 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 4

found limited instances where the investments component may 

have been rated higher than warranted. 

Additionally, we found two aspects of the CRA examination 

process warranting attention. First, some examiners could have 

been more proactive in assessing community credit needs. Eight of 

the 41 PE’s did not mention examiners meeting with community 

groups. Yet, these contacts are a primary means of identifying 

community credit needs. Second, in 30 of the 41 PE’s, examiners 

did not compare the thrift’s lending data in relation to the 

demographic make-up (i.e. number of LMI families in an 

assessment area) of the community. We believe such comparisons 

could enhance the PE in describing whether thrifts are meeting the 

needs of the community. 

Finally, we found that the OTS examination approach to nontraditional thrifts (thrifts with a primary office in one community, 

but delivering products through non-branch systems to a broader 

area) may not be clearly conveyed to or consistently applied by 

OTS examiners. We recognize that current regulations may not 

adequately address the operations of non-traditional thrifts, 

however the OTS examination procedures lack written specificity 

to ensure consistent application. 

We make 10 recommendations in this report to better ensure that 

PE reports provide an accurate assessment of CRA performance. 

Four recommendations are aimed at OTS seeking deliberations with 

the Federal Financial Institutions Examination Council (FFIEC) to 

consider revising CRA regulations or establishing additional 

guidance. Three recommendations deal with the need for more 

information in the PE’s as to how ratings are derived so that the 

rationale for assigned ratings is clearly conveyed and supported. 

Additional recommendations involve presenting lending data 

relative to assessment area demographics and requiring broader 

coverage of CRA in OTS’ quality assurance reviews. 

In response to our draft report, OTS concurred with our reported 

findings and recommendations and has committed to undertake 

various management actions. Under separate subsequent 

correspondence, OTS also advised us of other planned 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 5

management actions for two of the recommendations. Where 

applicable, OTS committed to initiate corrective action within a 

specified time frame. In other instances, management action was 

either already ongoing or tied to the FFIEC’s planned 2002 review 

of the CRA regulations. Also based on OTS’ response to the draft 

report, several revisions of a technical nature were made to the 

final report as applicable. For the full text of OTS’s response to the 

draft report, see Appendix 4. 

Background

The Community Reinvestment Act of 19771 (CRA) is intended to 

encourage banks and thrifts to meet the credit needs of the 

communities that those institutions serve. Federal banking 

regulators are also required to periodically evaluate these 

institutions' CRA performance in meeting the community's credit, 

investment and financial service needs, consistent with safe and 

sound banking practices. CRA specifically includes the credit and 

financial service needs of LMI neighborhoods. To enforce CRA, 

banking regulators are to take into account an institution's CRA 

performance when an institution files an application requiring 

regulatory approval on such matters as branches, mergers, 

consolidations, etc. 

OTS officials believe that CRA has led many thrifts to increase their 

lending and to expand financial services to all segments of society. 

However, there have been industry concerns about regulatory 

burdens and the difficulties of measuring CRA performance. These 

concerns led to revisions to CRA in 1995. The changes were 

developed jointly by the federal banking regulators in consultation 

with the banking industry and community organizations. The 

resulting CRA revisions aim at emphasizing the evaluation of an 

institution’s performance, promoting evaluation consistency, and 

minimizing the regulatory burden in complying with CRA. 

Under the CRA regulations, thrifts are to delineate one or more 

geographic assessment areas where they operate and within which 

examiners evaluate the thrift’s CRA performance. The size and 

 

1

 12 U.S.C. 2901. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 6

nature of assessment areas vary. For typical thrifts, an assessment 

area may encompass one or more census tracts within a city or the 

entire city. Large thrifts or those with remote branch offices may 

need to designate multiple assessment areas. For example, a thrift 

with interstate offices would need to delineate separate

assessment areas in each state and city in which it operates. 

Examiners are not expected to evaluate a thrift’s delineation of an 

assessment area, but rather, to see whether a delineated 

assessment area arbitrarily excludes LMI area(s). 

CRA Examinations

OTS conducts CRA examinations as a part of a thrift's overall 

compliance examination, which covers other areas such as 

discriminatory lending and consumer affairs. CRA examinations are 

conducted every 6 to 60 months, depending on the thrift's size and 

its prior CRA performance. Large thrifts and those with poor CRA 

performance are examined more frequently than small thrifts and 

those with adequate CRA performance. 2 

In evaluating CRA performance, examiners use information from 

various sources, including the thrift's records and local community 

groups. Information from local community, civic, or government 

leaders help examiners better understand the community's credit 

and financial service needs, as well as public perceptions of how 

well local thrifts are responding to those needs. OTS examiners 

also use information submitted by thrifts as required under the 

Home Mortgage Disclosure Act (HMDA). This data serves as the

basis for much of OTS’ lending analysis. As of the beginning of 

our review period, thrifts with total assets of more than $28 million 

were required to submit HMDA data. 

One important aspect of the 1995 CRA revisions was the 

establishment of different evaluation requirements for large and 

small institutions. For example, a large institution’s CRA 

performance is evaluated on it's lending, community investment, 

 

2

 Generally, a small institution is defined as having total assets of less than $250 million, and a large 

institution having total assets of $250 million or more.
OTS’ CRA Performance Evaluations (OIG-02-026) Page 7

and service to the community, whereas a small institution’s 

performance is primarily based on lending. 

The three CRA components are individually assessed and then 

assigned one of five possible ratings: Outstanding, High 

Satisfactory, Low Satisfactory, Needs to Improve, and Substantial 

Noncompliance. From those component ratings, examiners then 

assign a single composite CRA rating reflecting overall performance 

based on uniform guidance from the FFIEC. The four possible 

composite CRA ratings are Outstanding, Satisfactory, Needs to 

Improve, or Substantial Noncompliance. The results of the CRA 

examination along with OTS' analysis and information obtained 

during the examination are finalized in a PE report. 

During our review period, OTS was responsible for supervising over 

1,100 thrifts. These thrifts received 1,244 examinations, including 

multiple examinations for some thrifts. Table 1 shows the 

distribution of CRA ratings OTS assigned in the 1,244 

examinations, as well as a comparison to the other banking 

regulators. 

Table 1

Distribution of CRA Performance Ratings

July 1997 through June 2000

OTS Other Regulators

Rating Exam 

Count

Percentage Exam 

Count

Percentage

Outstanding 206 17% 1,657 19%

Satisfactory 985 79% 6,832 80%

Needs to Improve 45 3% 79 1%

Substantial

Noncompliance

8 1% 14 0%

 Total 1,244 100% 8,582 100%

Source: FFIEC and OIG analysis of CRA database

The other regulators include the Federal Deposit Insurance 

Corporation, the Federal Reserve, and the Office of Comptroller of 

the Currency. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 8

Findings and Recommendations

Finding 1 OTS Generally Meeting the Basic Legislative CRA 

Requirements

We found that the basic CRA legislative supervisory requirements 

are being met. CRA basically requires federal banking regulators 

to: 

• Assess an institution’s record of meeting the credit and deposit 

needs of its community; 

• Take such record into account in the evaluation of an 

application for a deposit facility by the institution; and 

• Prepare and make public a report of the examiners’ findings, 

conclusions and assigned ratings. 

OTS CRA examination reports were generally conducted timely, 

covered the required areas using regulatory criteria, appeared to 

consider CRA performance when acting on applications, and were 

readily available to the public.

OTS CRA Examinations Timely and Followed Regulatory Criteria

Using OTS' Examination Data System (EDS), we found that all 

required CRA examinations had largely been completed in a timely 

manner. The EDS showed that 1,244 examinations were 

conducted during our three-year review period (July 1, 1997 –

June 30, 2000). Of the 1,244 examinations, 138 were repeat 

examinations. Only 24 (0.019%) examinations were late. Of the 

24, 11 were late by one month or less; nine were late by two to 

six months, and the remaining four were late by more than six 

months. We believe that the extent of late examinations were 

minimal and due to understandable complexities such as thrifts 

with multi-state branches. 

Based on a review of 41 sampled thrifts, we also found that these 

CRA examinations were generally completed in accordance with 

the regulatory criteria for assessing each component as established 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 9

under 12 C.F.R. §563e. Table 2 below shows those few areas 

that were not always covered in the PE. 

Table 2

Summary of CRA Examination Coverage

CRA Performance Component & Underlying Criteria

Criteria

Coverage 

Rate (%)

Lending Component: 

 Number and amount of loans in the thrift’s assessment area 100%

 Geographic distribution of loans 95%

 Distribution of loans by borrower characteristics 95%

 Number and amount of community development loans 83%

 Thrift’s use of innovative or flexible lending practices 80%

Investment Component: 

 Dollar amount of qualified investments 97%

 Innovativeness or complexity of qualified investments 50%

 Responsiveness of qualified investments to credit and community

 development needs 97%

 Degree to which qualified investments were not routinely provided 

 by private investors 8%

Financial Service Component: 

 Distribution of branches among various income geographies 94%

 Thrift’s record of opening and closing branches 92%

 Availability and effectiveness of alternative delivery systems 94%

 Range of services provided in various income geographies 92%

 Extent to which thrift provides community development services 97%

 Innovativeness/responsiveness of community development service 6%

Source: OIG Analysis of Sample Thrifts

As Table 2 shows, there were three areas that examiners 

addressed 50 percent or less of the time. The responsible OTS 

official reasoned that if an area did not have an impact on the 

rating, then it was not necessary for the PE to specifically show 

that it was considered or covered in the examination. Rather than 

commenting on the underlying areas, the official was more 

concerned that the rating(s) were supported. 

We appreciate the desire to avoid apparent superfluous detail. 

However, the breadth of potential users of PE reports may not be 

equally versed on CRA. Accordingly, complete and full disclosure 

of the regulatory criteria underlying each rating component would 

better ensure a full understanding of how each rating had been 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 10

derived. Noting component areas that were not applicable should 

not be a reporting burden given the limited number of areas per 

component. 

Unclear How CRA Performance Taken Into Account in the 

Application Process

The only substantive enforcement sanction to CRA is that 12 

C.F.R. §563e.29 requires OTS to take into account a thrift’s CRA 

record prior to acting on an application submitted by the thrift. 

These applications cover a variety of different business activities 

such as changing or adding new lines of business, establishing or 

closing branches, and mergers. 

The regulation, however, does not specify how a thrift's CRA 

performance is to be taken into account or weighed in the 

application process. As a result, OTS exercises considerable 

subjective judgment when considering CRA performance in either 

approving or denying an application. OTS officials, industry 

representatives and community groups we met held a common 

belief that the CRA record could impact the ultimate decision.

Between January 1997 and December 2000, OTS processed about 

4,300 applications. Of these, 24 applications were submitted by 

thrifts with a less than Satisfactory CRA rating. Of the 24, OTS 

approved 21 applications. Three were withdrawn by the thrifts, 

thus eliminating the need for a regulatory action. Of the 21, four 

were approved because they were of a type that OTS automatically 

approves, such as changing to a state charter. Given the lack of 

specific regulatory criteria, we could not assess the merits of 17 

application approvals. We could not draw any conclusions or 

opinions as to whether current law or regulation provides sufficient 

sanctions when thrifts have less than satisfactory CRA ratings. 

Given the lack of evaluative criteria, we could not assess whether 

OTS appropriately considered the less than Satisfactory CRA 

ratings in the application process. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 11

OTS Ensuring PE’s Are Publicly Available 

12 C.F.R. §563e.43 requires thrifts to make copies of their most 

recent CRA evaluation available to the public. Each of the thrifts 

we visited had a copy of their PE available to the public. Also, 

several community group representatives we spoke to confirmed 

that PE’s were available to them when needed. In addition, we 

readily obtained copies of the PE’s for the 41 thrifts in our sample 

from OTS’ website. 

Recommendations

1. Given the wide breadth of potential users of PE reports, the 

OTS needs to better ensure complete and full disclosure as to

how examiners evaluated each component area in arriving at 

the component ratings. 

OTS Management Comment

OTS did not agree that the reported omissions in Table 2 were 

needed to fully understand how the component ratings were 

derived. Nevertheless, OTS stated they would raise this issue 

with the FFIEC committee conducting the 2002 review of the 

CRA regulations. 

OIG Comments

We believe that OTS’ proposed management action is 

responsive to the intent of the recommendation given the broad 

potential applicability for more uniform reporting by all affected 

institutions. In response to OTS’ view as to the necessity of 

complete disclosure, we have made several revisions from a 

technical perspective as applicable. However, we continue to 

believe that full and complete disclosure, as to how examiners 

derived a component rating relative to the regulatory criteria, 

would be less prone to improper impressions by users of PE’s 

than the absence of such discussion. The latter would be more 

prone to speculation given the omission of information. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 12

2. Given the lack of regulatory specificity, OTS should seek, 

through FFIEC interagency deliberations, further regulatory 

guidance as to how an institution’s CRA performance is to be 

considered and weighed in the application process. 

OTS Management Comment

OTS raised several legislative history issues suggesting that the 

original intent of CRA did not include establishing a minimum 

level of performance that might be used in acting on 

applications. Nevertheless, OTS stated they would raise this 

issue with the FFIEC committee conducting the 2002 review of 

the CRA regulations. 

OIG Comments

We believe that OTS’ proposed management action is 

responsive to the intent of the recommendation, given the 

potentially broad applicability affecting the other regulatory 

agencies enforcing CRA. 

Although OTS’ observations as to the original legislative intent 

of CRA is important to understand, the issue of whether 

effective sanctions exist to address poor CRA performance 

likely arose after the authorizing legislation. In fact, criticism of 

regulators for denying few applications on the basis of CRA 

performance was previously reported by the U.S. General 

Accounting Office (GAO) (Community Reinvestment Act 

Challenges Remain to Successfully Implement CRA, GAO/GGD96-23, November 1995). 

The GAO pointed out inconsistencies across regulators as to 

how applications were being approved relative to CRA 

performance. Some regulators approved applications with 

commitments, which explicitly tied an application’s approval to 

tangible improvement in CRA performance. Another regulatory 

practice was the use of conditional approvals of applications. 

Similar to commitments, conditional approvals required an 

institution to meet certain CRA conditions before the institution 

could consummate the applied transaction. GAO showed that 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 13

OTS seldom denied applications and, compared to the other 

regulators, seldom used conditional approvals. We believe that 

further regulatory guidance as to how CRA performance could 

be considered in the application process will lessen these 

inconsistencies and more closely approach addressing the 

lingering issue of CRA sanctions. 

3. In the interim, OTS should consider establishing internal written 

guidance to better ensure that CRA performance is taken into 

consideration in a consistent and uniform manner in the 

application process. Alternatively, OTS should consider 

covering this specific aspect of the application process through 

periodic internal quality reviews.

OTS Management Comment

OTS currently covers the role of CRA in the application process 

in their internal reviews. However, to enhance the application 

process and these reviews, OTS will prepare written guidance 

by April 2002 on how CRA performance should be considered 

when deciding covered applications. 

OIG Comment

We believe OTS’ planned management action addresses 

recommendation 3, if properly implemented. The additional 

written guidance should also better ensure consistency in the 

application process. 

Finding 2 Unsupported or Questionable CRA Ratings

In reviewing the 41 sampled CRA examinations, we could not 

validate lending component ratings for eight thrifts, found apparent 

inconsistencies with some investment ratings, and believe that 

some thrifts’ investment components may have been rated higher 

than warranted. These questionable ratings could be attributed to 

different causes. PE reports lacked sufficient information beyond a 

summarization of lending activity so that the ratings could be 

understood within the context of the thrifts’ local lending 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 14

conditions (i.e. performance context lacking). Examiners lacked 

sufficient criteria to evaluate investments activity; current 

examination practices allow broad interpretative discretion. 

Performance Context Lacking 

In evaluating CRA performance, examiners are not to rely solely on 

the level of lending alone, but also take into account information 

about the thrift, its competitors, community and peers. Specifically 

referred to in the regulations as "performance context," the 

examiner evaluates CRA performance in the context of the thrift's 

demographic characteristics within its assessment area, the thrift's 

known lending, investment and service opportunities, and the 

thrift's business products and strategies. In so doing, the examiner 

is to assess CRA performance in the context of the thrift's 

operating conditions, which the regulations recognize can vary 

across different thrifts. 

We found that for 33 (80%) of the 41 sampled PE reports, 

examiners provided sufficient performance context, which provided 

clear support for ratings. It should be noted that in these cases the 

ratings were easily supported, given that the thrifts typically had 

high levels of lending. The rationale for the ratings was also 

evident from the performance context. 

The other eight (20%) PE reports lacked sufficient performance 

context information. Consequently, we were unable to determine 

or validate how the examiner arrived at the CRA component 

ratings. Moreover, some of the statistical summary information 

gathered and reported without performance context surfaced some 

apparently inconsistent ratings across some thrifts. 

For example, one of the sampled thrift's lending was rated "Low 

Satisfactory," indicating an adequate performance, even though its 

lending data was lower than its peers. The only performance 

context discussed in the PE was that the thrift's..."loan distribution 

ratios within LMI geographies are significantly lower than the 

aggregate HMDA loan lenders in 1998," thus raising further 

question as to the Low Satisfactory rating. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 15

Table 3 below further illustrates how summary data alone does not 

provide sufficient support as to how a rating was derived. Instead, 

the lending component ratings seemed inconsistent given the 

lending information presented in the PE reports. 

Table 3

Similar Ratings For Varying Lending Activity

Thrift:

Lending Activity 1 2 3 4

Asset Size ($ in millions) $541 $495 $848 $901 

HMDA Lending ($ in millions)

 (% of Assets)

$348 

(64%)

$151 

(30%)

$205 

(24%)

$169

(19%) 

Comparison to Peers Based on

 Borrower Characteristics

Higher Lower Lower Lower

Comparison to Peers Based on

 Geographical Area

Lower Lower Lower Higher

Did PE Report Discuss

 Innovative Lending?

Yes Yes Yes Yes

Community Development

 Lending ($ in thousands)

 (% of Asset Size)

$259

(0.0005%)

$6,200

(0.013%)

- 0 - $933

(0.001%)

CRA Lending Rating Low

 Sat.

Low

 Sat.

High

 Sat.

High

 Sat.

 Source: OTS PE Reports 

Without performance context information, the summary data alone 

raises apparent inconsistencies in the ratings, and inevitably their 

validity. For example, thrifts 1 and 2 were of similar size and both 

received a "Low Satisfactory" CRA rating for the lending 

component. Yet, other than similar peer group lending based on 

geographical area, the other lending component areas were 

ostensibly quite different. For example, the lending volume varied 

by as much as 34% as a percent of total assets. Thrifts 3 and 4 

also raised similar questions given the lack of performance context 

information in the PE report. 

When asked about these cases, OTS officials admitted that in 

some cases examiners could have done a better job of explaining 

their ratings. However, they felt the PE’s generally provided the 

necessary information to justify the ratings, including all necessary 

data required by the regulation. Although they believed the 8 

ratings in question were correct, they did not provide further 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 16

explanation as to how the ratings were specifically derived in light 

of the accompanying lending information and absence of 

performance context information. Consequently, we were not 

able to independently validate the assigned ratings. 

Inconsistent CRA Investments Ratings

As with the lending component, we were unable to validate the 

basis or appropriateness of the CRA Investments component 

ratings for 17 (41%) of 41 thrifts. There were also some apparent 

rating inconsistencies across several thrifts based on the actual 

level of investments. We also found limited instances where the 

investment rating appeared higher than warranted, despite the 

regulatory flexibility afforded thrifts with statutory investment 

limitations. 

To evaluate the investment component, examiners use the 

following regulatory criteria: (a) dollar amount of qualified 

investments, (b) innovativeness or complexity of the investments, 

(c) responsiveness of investment to credit and community 

development needs, and (d) degree to which the investments are 

not routinely provided by private investors.3 Noticeably absent 

from the regulations are guidance for examiners to evaluate all the 

information gathered for the aforementioned criteria to arrive at a 

specific rating. Consequently, examiners have a lot of leeway to 

exercise subjective judgment in arriving at the rating. But without 

criteria and the absence of performance context information, we 

could not validate how investment ratings were derived, or their 

appropriateness, nor could we reconcile apparent inconsistencies. 

 

3

 12 C.F.R. 563e §23. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 17

Table 4 below illustrates that similar investment component ratings 

were given even though the level of investments varied widely. 

Table 4

Similar Investments Ratings for Varying Investment Activity 

Investments Activity Thrift 1 Thrift 2 Thrift 3

Asset Size ($ in millions) $535 $526 $161

Investments ($ in thousands)

 (% of Assets)

$562

(0.001%)

$27

(0.0001%)

$385

(0.002%)

Investment Rating Low 

Satisfactory

Low 

Satisfactory

Low 

Satisfactory

 Source: CRA PE Reports

As the table shows, thrifts 1 and 2 were of similar size and both 

received a rating of Low Satisfactory. Yet their level of 

investments was significantly different, both in absolute and 

relative terms. Thrift 1 investments were over 20 times greater 

than thrift 2. Investments made by thrift 3 raise further questions 

as to the rating consistency. In absolute terms, thrift 3 

investments were 15 times greater than thrift 2. The difference in 

investments is even greater in relative terms with thrift 3 assets 

being smaller than thrift 2 assets by over two thirds. 

We could not validate the basis or appropriateness of the 

investment ratings, given the absence of regulatory guidance as to 

what level of investment qualifies for a specific rating. Nor could 

we reconcile these apparent rating inconsistencies, given the 

absence of performance context information in the PE reports. 

Peer comparisons were not done because, unlike the lending 

component, examiners are not required to compare investments 

based on thrifts' peers. 

These rating validation difficulties were also echoed by thrifts we 

visited. For example, one thrift manager asked an OTS examiner 

what dollar amount of investment was needed to receive an 

“Outstanding” rating. However, the OTS examiner could not 

provide a specific answer. Another CRA officer, whose thrift 

received an "Outstanding" CRA rating, told us that the investment 

criterion was too vague and subjective. From reviewing other 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 18

thrifts' PE reports, the officer felt that the vague and subjective 

criterion might have contributed to "Inflated" ratings. 

OTS officials also acknowledge that the investment test is the 

most difficult to evaluate due to the lack of specific standards. On 

the other hand, officials also noted that it might be impractical to 

establish quantitative standards because of the different 

circumstances under which thrifts operate. For example, business 

strategies or availability of funds may limit investment levels. The 

officials believe that these same factors could limit the value of 

peer comparisons.

Thrifts Have Statutory Investment Limitations

Thrifts have limited statutory investment authority compared to 

banks, thus making it difficult to reasonably evaluate thrifts 

investments performance. The 1995 CRA revisions recognized this

limitation and a modification was made to permit thrifts with 

limited investment authority to receive a "Low Satisfactory" rating 

even if they had few or no qualified investments. However in 

these situations, thrifts must have a strong record of lending and 

community development loans. The modification is not intended to 

be a blanket exemption from the investments test. 

Of the 41 sampled thrifts, the investment component ratings for 

13 were based on lending activity. Most of the 13 had minimal or 

no investments. However, we believe that 3 of the 13 thrifts did 

not warrant their investment rating, given their lending and 

community development record. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 19

Table 5 below profiles the 13 thrifts with investments ratings 

based on lending activity. 

Table 5

Lending Profile of 13 Thrifts Receiving Investment Ratings 

Based on Lending Activity 

(Dollars in thousands)

Inst Investments

Lending

Rating

Community

Development 

Lending 

Met 

Strong 

Lending 

Criteria

Met 

Community 

Development 

Criteria

1 $3,290 Outstanding $10,300 Yes Yes

2 $0 Outstanding $1,600 Yes Yes

3 Not given High Sat. $7,300 Yes Yes

4 $367 High Sat. $1,500 Yes Yes

5 $40 High Sat. $398 Yes Yes

6 $24 Low Sat. $1,000 Yes Yes

7 $0 High Sat. $2,800 Yes Yes

8 $75 Low Sat. $10,400 No Yes

9 $30 Low Sat. $6,200 No Yes

10 $16 Low Sat. $450 No Yes

11 $13 Low Sat. $259 No Yes

12 $3 Low Sat. $0 No No

13 $1 Low Sat. $0 No No

 Source: OIG Analysis of sampled PE reports

The PE report for thrift 3 noted that the investments rating was

largely based on strong lending activity. However, rather than a 

Low Satisfactory rating, examiners assigned High Satisfactory, 

apparently based on strong lending and minimal investments. We 

were unable to determine how much, if any, actual investments 

had been made during the rating period. We believe there is no 

regulatory basis for deriving an investments rating in this manner, 

particularly in the absence of discernable investments. 

Thrifts 12 and 13 had neither strong lending nor strong community 

development lending to merit the Low Satisfactory investment 

rating. We used 12 C.F.R. §563e as criterion for lending activities. 

The regulation describes Low Satisfactory as “adequate” CRA 

performance. By contrast, Outstanding and High Satisfactory are 

defined as “excellent” and “good,” respectively. The regulations 

require that lending be strong or particularly effective to base the 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 20

investments rating on lending activity. Accordingly, we believe 

“strong and particularly effective lending,” is more consistent with 

Outstanding or High Satisfactory ratings rather than a Low 

Satisfactory rating. 

We asked OTS how Low Satisfactory lending performance met the 

regulation's strong lending requirement. OTS officials said they 

equated a Low Satisfactory rating as meaning strong and 

particularly effective lending. We believe that this interpretation is 

not consistent with regulation. We still question whether the Low 

Satisfactory investment ratings assigned to these 2 thrifts were 

warranted in light of the Low Satisfactory lending ratings and 

absence of any community development lending. 

Recommendations

4. To better ensure that PE reports provide sufficient explanation 

in support of how a rating was derived, OTS needs to ensure 

that performance context information is appropriately 

incorporated into the PE report. Consideration should be given 

to updating the General Report Guidelines, section 125, to 

include both additional guidance and minimal content on 

performance context. This would also include requiring 

additional narrative on how aggregate data presented in the PE 

report was assessed in arriving at a rating in relation to the 

performance context. 

OTS Management Comment

OTS concurred and stated they were testing a standard set of 

core tables developed by the FFIEC CRA Subcommittee. The 

tables are to be included in every PE for every agency. In these 

tables, OTS will present data on lending, investment and service 

tests as well as demographic information for each thrift and 

each metropolitan area in which it has branches. OTS believes 

the tables will provide guidance and minimal content regarding 

baseline information to be uniformly presented in all PE’s. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 21

OIG Comments

We believe OTS’ planned management action will address the 

intent of recommendation 4 if properly implemented. We 

should also clarify the intent of the recommendation, given 

OTS’ response to the draft report. We agree that inclusion of 

performance context should not be a stand-alone item, as OTS 

points out. Instead, the recommendation is intended to point 

out that greater OTS attention to effectively discussing 

performance context relative to each rated component will 

lessen the ambiguity as to how a rating was derived. In so 

doing, PE’s should provide additional clarity to users, such as 

the thrifts we visited who raised questions as to the basis for 

the investments component ratings. 

5. To lessen the subjectivity of the investment test, OTS should 

seek through the FFIEC interagency deliberations to establish 

more objective regulatory criteria as to how investments are to 

be assessed. 

OTS Management Comment

OTS concurred and reiterated that regulations lack guidance for 

examiners to evaluate the information gathered for the 

investment test criteria, in order to arrive at a specific rating. 

OTS stated that the investment test issue will be evaluated in 

the 2002 review of the CRA regulation. 

OIG Comments

We believe OTS’ planned management action through the 2002 

interagency review of CRA regulations will address the intent of 

recommendation 5. 

6. Given the inconsistent lending and investment ratings observed 

from the sampled thrifts, OTS should provide for quality 

assurance reviews of CRA examinations to include a broader 

analysis comparing inter and intra-regional examinations and PE 

reports for consistency. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 22

OTS Management Comment

OTS concurred and stated that during our CRA review, they had 

already expanded their quality assurance reviews to include PE’s 

for fiscal year 2000. In a separate correspondence, OTS also 

noted that Compliance Policy will review a representative 

sample of CRA PE’s for consistency in the implementation of 

any regulatory or interagency examination guidance changes 

arising from the 2002 CRA review process. 

OIG Comments

We believe that OTS’ ongoing expanded quality assurance 

reviews adequately address recommendation 6, and that 

planned management actions with respect to any subsequent 

FFIEC guidance from the 2002 interagency review of CRA 

regulations also address the intent of the recommendation. 

7. OTS should also seek through the FFIEC interagency 

deliberations to establish objective criteria and or clarification as 

to what constitutes strong lending and community development 

lending when these activities are used in support of a Low 

Satisfactory investment rating for thrifts with little or no 

qualifying investments. In the interim, OTS needs to establish 

internal guidelines clarifying the process to better ensure 

consistent treatment by examiners. 

OTS Management Comment 

OTS concurred and plans to establish internal guidelines to 

clarify the issue for examiners by April 1, 2002. OTS also 

noted that issues concerning the investment test and the 

difficulties in measuring performance are on the agenda for the 

2002 interagency CRA review. 

OIG Comment

We believe OTS’ planned corrective actions adequately address 

recommendation 7, if properly implemented. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 23

Finding 3 Examiner Assessment of Community Credit Needs Could 

Be Enhanced 

A telling perspective of a thrift's CRA lending performance is in the 

context of its community credit needs. OTS could enhance 

examiner assessments of community credit needs, and the 

reporting of it in the PE, by better ensuring examiners contact 

community groups, reporting the results of those contacts, and by 

describing thrift lending in relation to community demographics. 

Identifying Community Needs Through Community Contacts

OTS examination guidelines note that community contacts are an 

integral part of the CRA examination planning process. The 

guidelines state that community contacts enable examiners to 

better understand public perceptions as to how well local thrifts are 

responding to the credit needs of the community. Such contacts 

include community groups, and other leaders of the community 

within the assessment area. The results of these community 

contacts are to be included in the PE report. 

Of the 41 PE reports sampled, eight lacked documentation or 

discussion that examiners contacted community groups to assess 

the thrift's community credit needs. The remaining 33 PE reports 

mentioned that the examiner made community contacts. However, 

in 12 of the 33 cases, the PE simply mentioned that OTS 

examiners had made the contacts, but did not describe the nature 

or results of the community contacts. 

OTS officials acknowledged that community group contacts were 

vital and should be made anytime they performed a CRA 

examination. They believed that community contacts were actually 

made in those eight examinations cited but not reported because 

examiners felt that such discussions would not add value to the 

report. They felt the concerns and issues faced by the community 

were well known within the community, and therefore, it was not 

necessary to discuss them in the PE’s. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 24

We did not attempt to validate the issues and concerns within 

these eight communities. Nevertheless, we believe that full and 

complete disclosure of community contacts in the PE report would 

better ensure that users of PE reports understand community 

needs, and would provide an added perspective of the thrift's 

lending performance. Community members would also be assured 

that their views were accurately portrayed, and that examiners 

considered their views in assessing performance. 

Presenting Thrift Lending In Relation to Area Demographics

OTS guidance only requires PE’s to compare thrift lending to the 

lending performance of peers. The guidance does not require PE’s 

to compare thrift lending to area demographics. However, lending 

performance relative to peers alone may not sufficiently reflect 

whether a thrift's lending practices are meeting community needs. 

In 38 of the 41 cases in our sample, examiners compared the 

thrift’s lending data to its peers, as required by guidance. In 11 of 

41, examiners also compared aggregate lending data to the 

demographic make-up of the community. In so doing, the PE 

reports clearly indicated whether the thrifts were meeting the credit 

needs of the community. 

For the 30 cases without demographic comparison, the basis or 

appropriateness of a rating could be unclear and unconvincing. For 

example, one thrift's lending performance was rated outstanding 

with just over three percent of its loans to low-income families. 

This level of performance was deemed outstanding because it was 

comparable to the peers’ percentage of lending to low-income 

families. Although comparable to peers, the thrift's lending to lowincome families was relatively small when viewed with the 20 

percent composition of families in the low-income level for its 

assessment area. Given this apparent gap, it is unclear whether 

the thrift was effectively meeting the credit needs of this income 

group. 

OTS officials indicated that the intent of CRA was not for thrifts to 

completely meet the needs of the LMI families within the 

assessment area. Just because 20 percent of the families are 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 25

low-income does not mean that 20 percent of a thrift's loans 

should be to LMI families. However, we believe that unless the PE 

report discloses demographic information for context, PE report 

users may erroneously conclude that the credit needs of all relevant 

income groups are being met, particularly when those credit needs 

are not discussed. 

Recommendations

8. The OTS should improve controls to better ensure that 

examiners contact community groups and that the results of 

those contacts are more fully described in the PE report. 

OTS Management Comment

OTS concurred and stated that they have been working since 

1998 on an interagency community contact database to 

improve the process of gathering, sharing and utilizing 

community contact information. OTS stated that the project 

will continue and that in the meantime, OTS will continue to 

emphasize and demonstrate the importance of community 

contacts with examiners at every opportunity. 

OIG Comments

We believe that OTS’ cited management action adequately 

addresses recommendation 8. We also believe that the 

expanded quality assurance reviews noted previously above 

could also serve as an added internal control to better ensure 

that the nature of community group contacts are adequately 

discussed in the PE’s. 

9. The OTS should assess the value of requiring a comparison of 

thrift lending relative to assessment area demographics to 

enhance the performance context of a thrift's lending. 

Consideration needs to be given to more effectively describing 

area demographics without implying a required lending 

distribution. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 26

Management Comments

OTS indicated that the planned management actions to 

recommendation 4, in terms of making demographic data a part 

of the interagency core tables, would also address 

recommendation 9. OTS also committed to reviewing 

interagency instructions on what demographic information 

should be considered in evaluating CRA performance as a part 

of the 2002 interagency CRA review. 

OIG Comment

We believe that both of OTS’ planned management actions 

address the intent of recommendation 9. However, a part of 

OTS’ response to this recommendation reflected a 

misunderstanding of the recommendation. We did not intend 

that all PE’s include a comparison of lending levels to the 

population of LMI individuals. To the contrary, the 

recommendation was intended to afford OTS flexibility by 

recommending they assess the value of such comparisons so as 

to enhance the performance context of a PE. As we discussed 

on pages 24 and 25 of the report, there were ambiguities as to 

how a thrift was meeting the credit needs when viewed in the 

context of only a peer comparison despite the availability of LMI 

demographic information. And in those instances when OTS 

included such a discussion, the PE’s more clearly explained how 

the thrift was meeting a community’s credit needs. 

Finding 4 Clear Guidance Needed for Non-traditional Thrifts

The proliferation of non-traditional thrifts has raised the question of 

how to properly evaluate their CRA performance, given their nontraditional organizational structure, delivery platforms, and 

channels. Non-traditional thrifts are generally defined as those 

thrifts that have their primary office in one local community but 

conduct their business in a broader, regional, or national area. 

They may not even have typical branch offices. For example, 

some insurance companies are granted thrift charters and conduct 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 27

business through a network of agents. OTS personnel note a 

dramatic growth of thrifts delivering their products through nonbranch systems on a national or regional basis. 

The regulation (12 C.F.R. § 563e.41) provides for assessing a 

thrift’s CRA performance in the local community where the thrift is 

chartered. The regulation specifically states that the thrift’s 

assessment area will be in those areas where a thrift has deposittaking branches. Additionally, the regulation explicitly provides 

that the agencies will use the assessment area delineated by the 

thrift in evaluating the thrift’s performance. Further, the FFIEC

issued Interagency Questions and Answers on October 21, 1996 

providing additional guidance on when to consider loans made 

outside of an institution’s assessment area. The guidance states 

that favorable consideration will be given for loans to LMI persons

outside of an institution’s assessment area provided the institution 

has adequately addressed the needs of borrowers within its 

assessment area. 

For non-traditional thrifts, OTS does not limit its CRA evaluation to 

the regulatory defined assessment areas as designated by the 

thrift. Instead, the agency evaluates performance based on the 

broader areas where the thrift does business, provided that the 

thrift is adequately serving the needs of its designated assessment 

area. OTS believes that it is more realistic to measure CRA 

performance throughout the markets where the thrift does 

business, rather than just within the designated assessment area. 

Agency officials stated that this broader view of the service area 

better ensures that thrifts are meeting their CRA obligations to the 

communities they truly serve. 

OTS used this approach to evaluate three of six non-traditional 

thrifts in our sample of 41. According to agency officials, the OTS 

was the first of the four banking regulatory agencies to deal with 

the issue of non-traditional institutions. Further, the OTS 

supervises a larger number of non-traditional institutions than the 

other regulators and out of necessity was proactive in developing 

an examination approach. OTS believes their approach follows 

existing regulation and guidance, is more focused, and makes 

active use of available options. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 28

OTS demonstrated their approach toward non-traditional thrifts for 

the first time in a 1998 PE report of a nationwide lender. 

According to the PE report, all products and services were 

delivered through non-branch means. Examiners first determined 

the adequacy of CRA lending activity within their designated 

assessment area. Examiners concluded performance was 

adequate, given its performance context, then considered lending 

activity in the other areas reached by the thrift’s operations. The 

PE report shows that, based on the thrift’s good lending record to 

LMI areas outside their designated assessment area, OTS gave 

additional favorable consideration to the CRA lending component. 

On the other hand, an OTS official stated that OTS would not give 

unfavorable consideration for poor lending in LMI areas outside the 

designated assessment area. 

We found that the OTS approach to non-traditional thrifts, as

illustrated in the 1998 PE report, may not be clearly conveyed to, 

or consistently applied by OTS examiners. Out of six nontraditional thrifts in our sample, three evaluations involved further 

consideration of lending activity outside of the designated

assessment area, while the other three did not. However, the PE 

reports did not indicate why different approaches were used. 

Three of the thrifts received High Satisfactory CRA ratings in the 

lending component, two received Low Satisfactory, and the one

small institution received an overall rating of Satisfactory, as is the 

general standard with small thrifts. 

We recognize that current regulation does not clearly address the 

unique operating conditions of non-traditional institutions. 

Nevertheless, OTS' supervisory examination procedures lack 

written specificity to ensure consistent application by examiners 

when assessing non-traditional thrifts. 

Recommendation

10. The OTS should provide examiners with further 

guidance to ensure greater consistency in applying 

the agency’s approach to non-traditional thrifts. 
OTS’ CRA Performance Evaluations (OIG-02-026) Page 29

Management Comments

OCC concurred and pointed out that the assessment area 

issues raised by non-traditional institutions had already been 

raised by the FFIEC as a part of the 2002 CRA review. In the 

interim, OTS plans to issue a Compliance Alert to their 

examiners on the evaluation of non-traditional institutions 

before December 31, 2001. It is hoped that this will also 

supplement prior training provided over the last two years on 

this aspect of CRA examinations.

OIG Comment

We believe that OTS’ planned management action adequately 

addresses recommendation 10. 

******

We would like to extend our appreciation to OTS for the 

cooperation and courtesies extended to our staff during the review. 

If you have any questions, please contact me at (415) 977-8810, 

extension 222. Major contributors to the report are listed in 

Appendix 4. 

/S/

Benny W. Lee

Regional Inspector General for Audit
Appendix 1

Objectives, Scope and Methodology

OTS’ CRA Performance Evaluations (OIG-02-026) Page 30

The objective of our audit was to determine whether OTS PE 

reports provide an accurate measure of thrift CRA performance. 

More specifically, we focused on factors affecting the CRA ratings 

of large thrifts. We also sought to determine whether OTS 

examiners were complying with CRA implementation regulations 

and OTS examination guidelines. This is the second in a series of 

OIG audits of regulatory agencies conducting CRA examinations. 

Previously, we conducted a 1998 review of OCC’s implementation 

of new CRA performance standards for small banks.4 Due 

professional care requires us to follow-up on known findings and 

recommendations from previous audits that could have an effect on 

current audit objectives, and to determine whether agency officials 

have taken prompt and appropriate corrective actions. 

To achieve this objective, we judgmentally selected a sample of 41 

thrifts and reviewed the CRA examinations conducted between 

July 1, 1997 and June 30, 2000. The thrifts in our sample were 

selected from three of the five OTS regions: Northeast, West, and 

Central. We chose 34 large thrifts (asset size $250 million or 

more), including the two largest thrifts in each region. In addition, 

we chose 7 small thrifts (asset size less than $250 million). The 

41 thrifts are detailed in Appendix 2. 

For each thrift sampled, we reviewed the most current PE. We 

also reviewed supporting examination work papers for 6 thrifts (2 

in each region) in order to validate data contained in the PE’s. 

Additionally, we validated selected data in the PE reports for 10 

other thrifts by comparing the PE data with data retrieved from the 

CRA Wiz reporting system. 

For questions that could not be resolved directly by reading the PE 

report or the supporting workpapers, we sought explanations from 

responsible OTS regional examination staff and managers. To 

understand some of the national CRA issues and the OTS 

examination policy, we interviewed OTS headquarters officials, as 

well as regional Compliance and CRA officers. 

 

4 The Office of the Comptroller of the Currency Needs to Improve its Implementation of the Community 

Reinvestment Act Small Bank Performance Standards, OIG-98-091, May 28, 1998. 
Appendix 1

Objectives, Scope and Methodology

OTS’ CRA Performance Evaluations (OIG-02-026) Page 31

In order to gain further understanding of the CRA program, 

examination issues, and individual perspectives on these issues, we 

spoke with representatives of five thrifts and seven community 

groups in the OTS regions we visited. 

We conducted our audit between June 20, 2000 and June 25, 

2001 in accordance with generally accepted government auditing 

standards. 
Appendix 2

Thrifts Sampled for OIG Review

OTS’ CRA Performance Evaluations (OIG-02-026) Page 32

CRA Ratings

Thrift

Asset Size

($ in 

millions)

Date of

PE 

Report

Overall Lending Invest Service

1 $ 535 03/07/00 Sat Low Sat Low Sat High Sat

2 25,000 10/13/99 Sat High Sat High Sat High Sat

3 22,600 11/15/99 Out Out Out Out

4 848 08/30/99 Sat High Sat Low Sat Low Sat

5 773 01/19/99 Needs Needs Needs Needs

6 2,400 04/26/99 Sat High Sat Low Sat High Sat

7 479 09/20/99 Sat High Sat Low Sat Low Sat

8 526 04/05/99 Sat Low Sat Low Sat Low Sat

9 719 11/01/99 Sat Low Sat Low Sat Low Sat

10 2,300 06/21/99 Sat High Sat Out Low Sat

11 628 01/26/98 Sat Out Low Sat High Sat

12 426 04/19/99 Sat High Sat Low Sat Low Sat

13 398 03/13/00 Sat Out Low Sat High Sat

14 63 02/07/00 Subst. n/a n/a n/a

15 210 11/16/98 Needs n/a n/a n/a

16 443 03/22/99 Sat High Sat Low Sat High Sat

17 405 01/25/99 Sat Low Sat Low Sat High Sat

18 901 01/25/99 Sat High Sat Low Sat Low Sat

19 415 12/14/98 Sat n/a n/a n/a

20 672 06/21/99 Sat Low Sat High Sat High Sat

21 495 03/22/99 Sat Low Sat Low Sat High Sat

22 32,081 07/20/98 Out Out Out Out

23 70,000 07/28/98 Out Out Low Sat Out

24 639 09/14/98 Sat n/a n/a n/a

25 54 05/17/99 Needs n/a n/a n/a

26 56 12/20/99 Sat n/a n/a n/a

27 87 12/15/99 Sat n/a n/a n/a

28 1,300 05/17/99 Sat High Sat High Sat Out

29 541 01/25/99 Sat Low Sat Low Sat Low Sat

30 142 01/10/00 Needs n/a n/a n/a

31 1,580 01/10/00 Sat Low Sat Low Sat High Sat

32 1,020 04/20/98 Sat Low Sat Low Sat High Sat

33 161 03/20/00 Sat Low Sat Low Sat Low Sat

34 353 09/21/98 Sat High Sat Low Sat Low Sat

35 784 11/03/97 Sat Low Sat Low Sat High Sat

36 19,900 04/06/98 Sat High Sat High Sat High Sat

37 16,500 05/18/98 Out Out High Sat High Sat

38 309 03/20/00 Sat Low Sat Low Sat High Sat

39 473 01/04/00 Sat Out Low Sat Low

40 1,000 09/29/97 Sat Low Sat Low Sat Low Sat

41 1,700 12/06/99 Sat High Sat Low Sat High Sat

Legend: Out - Outstanding, Sat - Satisfactory, Needs - Needs to Improve, 

Subst - Substantial Noncompliance, n/a - not applicable

Source: OTS PE Reports
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 33
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 34
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 35
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 36
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 37
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 38
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 39
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 40
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 41
Appendix 3

Management Comments

OTS’ CRA Performance Evaluations (OIG-02-026) Page 42
Appendix 4

Major Contributors to This Report

OTS’ CRA Performance Evaluations (OIG-02-026) Page 43

Western Region

Joseph Eom, Auditor-in-Charge

John Mansfield, Auditor
Appendix 5

Report Distribution

OTS’ CRA Performance Evaluations (OIG-02-026) Page 44

The Department of the Treasury

Under Secretary, Office of Domestic Finance

Assistant Secretary, Office of Financial Institutions 

Director, Office of Strategic Planning

Director, Office of Accounting and Internal Control

Office of Thrift Supervision

Director

Regional Director, Western Region

Regional Director, Central Region

Regional Director, Northeast Region

Director, Internal Review

Director, Compliance Policy 

Office of Management and Budget

OIG Budget Examiner