Attachment to CA 13-20

1 | Page

CONSUMER COMPLIANCE AND COMMUNITY 

REINVESTMENT ACT (CRA) EXAMINATION MANDATES

FREQUENCY FOR STATE MEMBER BANKS 

FREQUENCY FOR BANKS WITH ASSETS

≥ $350 MILLION and < $ 1 BILLION

Compliance

Rating

CRA Rating Next

Compliance

Examination

Next CRA

Examination

1 or 2 Outstanding or

Satisfactory

36 months 36 months

1 or 2 Needs to Improve or

Substantial

Noncompliance

36 months 12 months

3, 4, or 5 Outstanding or

Satisfactory

12 months 36 months

3, 4, or 5 Needs to Improve or

Substantial

Noncompliance

12 months 12 months

FREQUENCY FOR BANKS WITH ASSETS < $350 MILLION

Compliance

Rating

CRA Rating Next

Compliance

Examination

Next CRA

Examination

1 or 2 Outstanding 60 months No earlier than 60

months

1 or 2 Satisfactory 48 months No earlier than 48

months

1 or 2 Needs to Improve or

Substantial

Noncompliance

48 months 12 months

3, 4, or 5 Outstanding 12 months No earlier than 60

months

3, 4, or 5 Satisfactory 12 months No earlier than 48

months

3, 4, or 5 Needs to Improve or

Substantial

Noncompliance

12 months 12 months
Attachment to CA 13-20

2 | Page

FREQUENCY FOR BANKS WITH ASSETS ≥ $1 BILLION

Compliance

Rating CRA Rating

Next

Compliance

Examination

Next CRA

Examination

1 or 2 Outstanding or

Satisfactory

24 months 24 months

1 or 2 Needs to Improve or

Substantial

Noncompliance

24 months 12 months

3, 4, or 5 Outstanding or

Satisfactory

12 months 24 months

3, 4, or 5 Needs to Improve or

Substantial

Noncompliance

12 months 12 months

FREQUENCY FOR STATE MEMBER BANKS UNDER CONTINUOUS SUPERVISION

State member banks that are large (generally with total assets of more than $10 billion) or complex 

may be placed under continuous supervision. These banks are continuously monitored with 

consumer compliance targeted reviews conducted over time. A report summarizing the results of 

targeted reviews is generally issued at the close of those reviews. A roll-up of those reviews into a 

comprehensive report is generally provided to the supervised institution once each year. CRA 

examinations are conducted at a point-in-time based on the bank’s asset size and rating.

FREQUENCY FOR STATE MEMBER BANKS DESIGNATED AS SPECIAL PURPOSE 

BANKS EXEMPT FROM CRA1

Assessments are conducted to determine whether a special purpose bank engages in activities subject 

to consumer protection laws and regulations (covered activities), including the CRA. A special 

purpose bank that did not engage in activities subject to the consumer protection laws and regulations 

at its most recent consumer compliance assessment will be subject to another assessment in 48 

months. If the assessment determines that a special purpose bank does engage in covered activities, 

the Reserve Bank should conduct a consumer compliance examination within 90 days of the 

assessment and assign a rating. A special purpose bank that engages in activities subject to consumer 

protection laws is subject to examination at a frequency based on its asset size and most recent 

compliance rating. 

 1 The CRA regulations provide an exemption from CRA for “special purpose banks,” which do not perform commercial 

or retail banking services by granting credit to the public in the ordinary course of business, other than as incidental to 

their specialized operations.
Attachment to CA 13-20

3 | Page

FREQUENCY FOR ASSESSMENTS AND EXAMINATIONS

FOR DESIGNATED SPECIAL PURPOSE BANKS EXEMPT FROM CRA

Compliance Rating Assets < $350 Million Assets ≥350 Million 

and < 1 Billion 

Assets ≥ $1 Billion 

Not Rated 48 months 48 months 48 months

1 60 months 36 months 24 months

2 48 months 36 months 24 months 

3, 4, or 5 12 months 12 months 12 months

FREQUENCY FOR NON-STATE MEMBER BANK ENTITIES REGULATED BY THE 

FEDERAL RESERVE2

The following non-state member bank entities are regulated by the Federal Reserve and are subject to 

assessments and examinations: 

U.S. Offices (Branch and Agency) of Foreign Banks

• Uninsured state agencies – USA

• Uninsured state branch – USB 

Edge Act Corporations

• Edge Corporation-Banking – EDB

• Edge Corporation-Domestic Branch – EBR 

• Edge Corporation-Investment – EDI 

Article XII New York Investment Companies – NYI 

Agreement Corporations

• Agreement Corporation – Investment – AGI 

• Agreement Corporation – Banking – AGB 

Non-Deposit Trust Companies – MTC (Members only) 

Assessments are conducted to determine whether the non-state member bank entity engages in 

activities subject to consumer protection laws and regulations, including the CRA.3

 A non-state

member entity that did not engage in activities subject to the consumer protection laws and 

regulations at its most recent consumer compliance assessment will be subject to another assessment 

in 48 months. If the assessment determines that the non-state member entity does engage in covered 

activities, the Reserve Bank should conduct a consumer compliance examination within 90 days of 

the assessment and assign a rating. A non-state member bank entity that engages in covered activities 

is subject to examination based on its asset size and most recent compliance rating. 

 2 In prior guidance (e.g. CA 03-12), U.S. Offices (Branch and Agency) of Foreign Banks, Edge Act Corporations, Article 

XII Investment Companies, and Agreement Corporations were referred to as foreign banking organizations (FBOs). 3 An uninsured state branch of a foreign banking organization may be subject to the CRA if the branch was acquired from 

an insured bank and was located in a State in which the FBO does not maintain a branch; and the FBO does not limit its 

deposit-taking to foreigners (See 12 CFR 228.11(c)).
Attachment to CA 13-20

4 | Page

FREQUENCY SCHEDULE FOR ASSESSMENT AND EXAMINATIONS OF 

NON-STATE MEMBER BANK ENTITIES

Compliance Rating Assets < $350 Million Assets ≥350 Million 

and < 1 Billion 

Assets ≥ $1 Billion 

Not Rated 48 months 48 months 48 months

1 60 months 36 months 24 months

2 48 months 36 months 24 months 

3, 4, or 5 12 months 12 months 12 months

GENERAL RULES 

Calculating Examination Mandates and Determining When a Bank Becomes Subject to New 

Frequency Schedules

Mandated consumer compliance and CRA examination start dates for the next examination are

calculated after each examination, based on the examination close date. The assets reported as of 

December 31st of the two year end dates prior to the examination close date will be used to calculate 

examination frequency. A bank will be placed on the appropriate frequency schedule based on assets 

reported for the two year end dates and the compliance and CRA ratings.

4

 

Generally, a bank will remain on the frequency schedule, based on two consecutive year-end assets,

even if assets change between examinations. However, if a bank’s assets decrease to less than $250 

million during the interval between examinations, the next CRA examination (and the consumer 

compliance examination assuming the bank’s compliance rating is 1 or 2) should be scheduled to 

occur no earlier than either 60 or 48 months (depending on the bank’s CRA rating) from the date of 

the last CRA examination. This change should be made immediately to ensure compliance with the 

Gramm-Leach-Bliley Act of 1999 (GLBA). GLBA set the minimum interval for CRA examinations 

of banks with assets less than $250 million rated satisfactory or outstanding at 48 and 60 months, 

respectively. 

Meeting Examination Mandates

An examination mandate will be considered met as long as the start date of the examination is no 

more than 90 days past the mandated start date. From time to time, Reserve Banks may find it 

necessary to reschedule a mandated examination event beyond 90 days as a result of various 

unexpected conditions related to staffing, new state member banks, or other factors affecting 

resources. These situations should be discussed with the appropriate Division of Consumer and 

Community Affairs (C&CA) Oversight Analyst. Provided the Oversight Analyst and Reserve Bank 

staff reach an agreement on the timing of the examination or monitoring event, the mandate will be 

considered met.

 4 If the assets from the two prior year-end dates fall into different frequency schedules, the year-end assets for the third 

year prior will be used to calculate the examination frequency. If assets are unavailable for either of these dates at the 

close of an examination, the year-end assets for the third year prior to the examination close date will also be used.
Attachment to CA 13-20

5 | Page

Examination Mandate Flexibility

CRA: According to GLBA, a bank with assets less than $250 million may be subject to more 

frequent CRA examinations (i.e., earlier than 60 or 48 months) for reasonable cause. Issues that 

could negatively affect a bank’s CRA rating that are identified through ongoing supervision activities

or other contact with a bank should be discussed with the Reserve Bank’s C&CA Oversight Analyst.

A decision to accelerate the date of the next CRA examination for these banks will be rare. 

For banks with assets greater than or equal to $250 million, a Reserve Bank may conduct a CRA 

examination in advance of the examination mandate date since the GLBA frequency requirements do 

not apply to banks with assets greater than or equal to $250 million. 

Compliance: A compliance examination may be accelerated, or another supervisory event triggered, 

for any size bank if significant changes are identified that raise an immediate heightened sense of 

supervisory concern or that elevates the level of residual risk of a material product or of the 

institution as a whole.

Synchronization of Examinations

To the extent possible, consumer compliance and CRA examinations should be conducted 

simultaneously. In certain circumstances, it will not be possible to conduct simultaneous 

examinations. For example, if a bank with assets less than $350 million has a compliance rating of 

3, 4, or 5 and a CRA rating of Outstanding, the consumer compliance examination will be conducted 

in 12 months and the CRA examination will be conducted in 60 months. Reserve Banks should 

determine the best way to resynchronize the examinations and should do so as quickly as possible. 

The appropriate C&CA Oversight Analyst should be consulted in these cases.

De Novo Banks

The Reserve Bank should conduct an advisory visit as soon as practical, but no later than six months

from the date of membership, to develop a preliminary assessment of a de novo state member bank’s 

consumer compliance management program. The results of the advisory visit should be considered 

when planning the first examination of the startup institution. The Reserve Bank should conduct the 

first consumer compliance examination within 12 months and the first CRA examination within 24 

months of the date the institution becomes a state member bank.

Charter Conversions

Banks and thrifts that convert to Federal Reserve membership are subject to the same frequency rules 

as existing state member banks. The close date and rating of the last consumer compliance and CRA 

examinations by the bank’s previous regulator should be used to determine the date of the first 

Federal Reserve consumer compliance examination. The first Federal Reserve supervisory event 

could be simultaneous consumer compliance and CRA examinations or a separate consumer 

compliance or CRA examination.
Attachment to CA 13-20

6 | Page

If the previous regulator did not conduct simultaneous consumer compliance and CRA examinations,

the Reserve Bank should synchronize the examinations as soon as possible. The current compliance 

and CRA ratings and the date of the last examinations should be considered and the Reserve Bank’s 

C&CA Oversight Analyst should be consulted when making this determination.

If the due date for the first Federal Reserve examination of a bank converting to Federal Reserve 

membership has already passed, Reserve Banks should conduct the consumer compliance and/or 

CRA examination within 12 months of the date on which the institution becomes a state member 

bank.

In the event the bank’s previous regulator never conducted a consumer compliance or CRA 

examination, the Reserve Bank should conduct the first Federal Reserve consumer compliance and 

CRA examinations within 12 months of the date on which the institution becomes a state member 

bank.