Large Institution CRA Examination Procedures

OCC, FRB, and FDIC April 2014

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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
Large Institution CRA Examination Procedures

OCC, FRB, and FDIC April 2014

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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.

2

 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.
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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 
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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 deposittaking (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 
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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;
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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;
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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
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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 upperincome 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 
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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 lowand 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: 
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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 
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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. 
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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 upperincome 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. 
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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; 
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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 upperincome 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. 

 3

 The reference to MSA may also reference MD.
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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].
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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).
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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 lendingrelated 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.
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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.
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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).
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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).
21

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.