Strategic Plan CRA Examination Procedures 

OCC, FRB, FDIC February 2006 

COMMUNITY REINVESTMENT ACT 

EXAMINATION PROCEDURES FOR INSTITUTIONS WITH STRATEGIC 

PLANS 

Examination Scope 

1. For institutions with more than one assessment area, identify assessment areas for full 

scope review. To select one or more assessment areas for full scope review, analyze 

prior performance evaluations, available community contact materials, reported lending 

data and demographic data on each assessment area and consider factors such as: 

a. The level of the institution's lending, investment and service activity in the different 

assessment areas, including low- and moderate-income areas, designated disaster 

areas, or distressed or underserved nonmetropolitan middle-income geographies 

designated by the Agencies (Footnote 1. The Board of Governors of the Federal Reserve System, The Federal Deposit Insuranc

Office of the Comptroller of the Currency) based on (a) rates of poverty, unemployment, and 

population loss or (b) population size, density, and dispersion (Footnote 2. A list of distressed or underserved nonmetropo

at www.ffiec.gov. 

); 

b. The number of other institutions in the different assessment areas and the importance 

of the institution under examination in meeting credit needs in the different 

assessment areas, particularly in areas with a limited number of financial service 

providers; 

c. The existence of apparent anomalies in the reported lending data for any particular 

assessment area(s); 

d. The time since the assessment area(s) most recently received a full scope 

examination; 

e. Performance that falls short of plan goals based on a review of available data; 

f. The institution's prior CRA performance in the different assessment areas; and 

g. Comments from the public regarding the institution's CRA performance. 

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2. For interstate institutions, a rating must be assigned for each state where the institution 

has a branch and in every multistate MSA where the institution has branches in two or 

more of the states that comprise that multistate MSA. Select one or more assessment 

areas in each state for examination using these procedures. 

Performance Context 

4. Review the institution's public file for any comments received by the institution or the 

agency since the last CRA performance evaluation that assists in evaluating the 

institution's record of meeting plan goals. 

5. Consider any information that the institution provides on its record of meeting plan goals. 

6. Contact local community, governmental or economic development representatives to 

update or supplement information about the institution's record of meeting plan goals. 

7. As necessary, consider any information the institution or others may provide on local 

community and economic conditions that may affect the institution's ability to meet plan 

goals or otherwise assist in the evaluation of the institution. 

Performance Criteria 

1. Review the following: 

a. The approved plan and approved amendments; 

b. The agency's approval process files; and 

c. Written comments from the public that the institution or the agency received since the 

plan became effective. 

2. Determine whether the institution achieved its performance goals for each assessment 

area examined. 

a. Review the plan's measurable annual goals for each performance category and 

assessment area(s) to be reviewed. 

b. Obtain information and data about the institution's actual performance for the period 

that has elapsed since the previous examination. 

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c. Compare the plan goals for each assessment area reviewed to the institution's actual 

performance since its last examination in each assessment area reviewed to determine 

if all of the plan's goals have been met. 

3. If any goals were not met, form a conclusion as to whether the plan goals were 

"substantially met." In doing so, consider the number of unmet goals, the degree to which 

the goals were not met, the importance of those goals to the plan as a whole, and the 

reasons why the goals were not met (e.g., economic factors beyond the institution's 

control). 

4. Discuss preliminary findings with management. 

5. Summarize conclusions about the institution's performance. 

Ratings 

These instructions assume that the strategic plan covers all of the institution's assessment areas. 

If not, the analysis of performance for the assessment area(s) covered by the strategic plan must 

be combined with the analyses for assessment areas that were subject to other assessment 

method(s) in order to assign a rating. 

1. Group the analyses of the assessment areas examined by MSA (Footnote 3. The reference to MSA may also refe

) and nonmetropolitan 

areas within each state where the institution has branches. If an institution has branches in 

two or more states of a multi-state MSA, group the assessment areas that are in that 

MSA. 

2. If the institution has substantially met its plan goals for a satisfactory rating or, if 

applicable, an outstanding rating, in all assessment areas reviewed, summarize 

conclusions about the institution's performance in each MSA and the nonmetropolitan 

area of each state in which an assessment area was examined using these procedures. 

Assign the appropriate preliminary rating for the institution and, as applicable, each state 

or multistate MSA and proceed to Step 6, below. 

3. If the institution did not substantially meet its plan goals in each assessment area, check 

to determine if the institution elected in its plan to be evaluated under an alternate 

assessment method. 

a. If the institution did not elect in the plan to be evaluated under an alternate 

assessment method, assign a "Needs to Improve" or "Substantial Noncompliance" 

rating to those assessment areas in which plan goals were not substantially met, 

depending on the number of goals missed, the extent to which they were missed, and 

their importance to the plan overall. 

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b. If the institution elected in its plan to be evaluated under an alternate assessment 

method, perform the appropriate procedures to evaluate and rate the institution's 

performance in those assessment areas in which the institution did not meet plan 

goals. 

4. For institutions operating in multiple assessment areas, determine the relative importance 

of the assessment areas reviewed in forming conclusions for each MSA and the 

nonmetropolitan area within each state and for any multistate MSA where the institution 

has branches in two or more states. In making that determination, consider: 

a. The significance of the institution's activities in each compared to the institution's 

overall activities; 

b. The lending, service, and investment opportunities in each; 

c. The significance of the institution's loans, qualified investments, and lending-related 

services, as applicable, for each, particularly in light of the number of other 

institutions and the extent of their activities in each; and 

d. Demographic and economic conditions in each. 

5. For an institution operating in multiple MSAs or nonmetropolitan areas in one or more 

states or multi-state MSAs, assign a preliminary rating for each state and multi-state 

MSA. To determine the relative significance of each MSA and nonmetropolitan area to 

the rating in a state, consider: 

a. The significance of the institution's activities in each compared to the institution's 

overall activities; 

b. The lending, service, and investment opportunities in each; 

c. The significance of the institution's loans, qualified investments, and lending-related 

services, as applicable, for each, particularly in light of the number of other 

institutions and the extent of their activities in each; and 

d. Demographic and economic conditions in each. 

6. For institutions with operations in more than one state, assign a preliminary overall 

rating. In determining the relative significance of the institution's performance in each 

state or multistate MSA to its overall rating consider: 

a. The significance of the institution's activities in each compared to the institution's 

overall activities; 

b. The lending, service, and investment opportunities in each; 

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c. The significance of the institution's loans, qualified investments, and lending-related 

services, as applicable, for each, particularly in light of the number of other 

institutions and the extent of their activities in each; and 

d. Demographic and economic conditions in each. 

7. Review the results of the most recent compliance examination and determine whether 

evidence of discriminatory or other illegal credit practices that violate an applicable law, 

rule, or regulation should lower the institution’s overall CRA rating or, if applicable, its 

CRA rating in any state or multi-state MSA.4 If evidence of discrimination or other 

illegal credit practices in any geography by the institution, or in any assessment area by 

any affiliate whose loans were considered as part of the institution’s lending 

performance, was found, consider: 

a. The nature, extent, and strength of the evidence of the practices; 

b. The policies and procedures that the institution (or affiliate, as applicable) has in 

place to prevent the practices; 

c. Any corrective action the institution (or affiliate, as applicable) has taken, or has 

committed to take, including voluntary corrective action resulting from selfassessment; and 

d. Any other relevant information. 

8. Discuss conclusions with management and assign a final rating to the institution and state 

or multi-state MSA ratings, as applicable, considering the preliminary rating and any 

evidence of discrimination and other illegal credit practices. 

9. Write comments for the public evaluation and the examination report. 

Public File Checklist 

1. There is no need to review each branch or each complete public file during every 

examination. In determining the extent to which the institution's public files should be 

reviewed, consider the institution's record of compliance with the public file requirements 

in previous examinations, its branching structure and changes to it since its last 

examination, complaints about the institution's compliance with the public file 

requirements, and any other relevant information. 

4 “Evidence of discriminatory or other illegal credit practices” includes, but is not limited to: (a) Discrimination 

against applicants on a prohibited basis in violation, for example, of the Equal Credit Opportunity Act or the Fair 

Housing Act; (b) Violations of the Home Ownership and Equity Protection Act; (c) Violations of section 5 of the 

Federal Trade Commission Act; (d) Violations of section 8 of the Real Estate Settlement Procedures Act; and (e) 

Violations of the Truth in Lending Act regarding a consumer’s right of rescission. 

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2. In any review of the public file undertaken, determine whether branches display an 

accurate public notice in their lobbies, a complete public file is available in the 

institution's main office and at least one branch in each state, and the public file available 

in the main office and in each state contains: 

a. A copy of the approved strategic plan; 

b. All written comments from the public relating to the institution's CRA performance 

and any responses to them for the current and preceding two calendar years (except 

those that reflect adversely on the good name or reputation of any persons other than 

the institution); 

c. The institution's most recent CRA Performance Evaluation; 

d. A map of each assessment area showing its boundaries and, on the map or in a 

separate list, the geographies contained within the assessment area; 

e. A list of the institution's branches, branches opened and closed during the current and 

each of the prior two calendar years, their street addresses and geographies; 

f. A list of services (loan and deposit products and transaction fees generally offered, 

and hours of operation at the institution's branches), including a description of any 

material differences in the availability or cost of services between those locations; 

g. The institution's CRA Disclosure Statement(s) for the prior two calendar years; 

h. A quarterly report of the institution's efforts to improve its record if it received a less 

than satisfactory rating during its most recent CRA examination; 

i. HMDA Disclosure Statements for the prior two calendar years for the institution and 

for each non-depository affiliate the institution has elected to include in assessment of 

its CRA record, if applicable; 

j . The number and dollar amount of consumer loans, for large banks, if applicable; and 

k. The loan-to-deposit ratio, for small institutions. 

3. In any branch review undertaken, determine whether the branch provides the most recent 

public evaluation and a list of services generally available at its branches and a 

description of any material differences in the availability or cost of services at the branch 

(or a list of services available at the branch). 

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