PUBLIC DISCLOSURE. April 13, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION. CenterState Bank Central Florida, N.A. Charter Number 21730
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1 O SMALL BANK Comptroller the Currency Administrator National Banks Washington, DC PUBLIC DISCLOSURE April 13, 2009 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION CenterState Bank Central Florida, N.A. Charter North John Young Parkway Kissimmee, Florida Office the Comptroller the Currency North Florida Field Office 8375 Dix Ellis Trail, Suite 403 Jacksonville, Florida NOTE: This document is an evaluation this institution s record meeting the credit needs its entire community, including low- and moderate-income neighborhoods consistent with safe and sound operation the institution. This evaluation is not, nor should it be construed as, an assessment the financial condition this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion the federal financial supervisory agency concerning the safety and soundness this financial institution.
2 INSTITUTION'S CRA RATING: This institution is rated Outstanding. CenterState Bank Central Florida s (CSBCFL) average loan-to-deposit ratio is reasonable and comparable to peer group averages. A substantial majority business lending occurs in the assessment area. CSBCFL s lending activities show excellent penetration among businesses different sizes. The geographic distribution business lending in the assessment area is excellent. 1
3 DESCRIPTION OF INSTITUTION CenterState Bank Central Florida (CSBCFL) was established in September 1989 as First National Bank Osceola County. On June 30, 2000, the bank was acquired by CenterState Banks Florida, Inc., a multi-bank holding company. The bank changed its name to CSBCFL in the latter part 2006; however, it still remains a separate bank operating as a wholly-owned subsidiary the holding company. CSBCFL, headquartered in Kissimmee, Florida, is the only local bank with headquarters in Osceola County. The bank has six full service fices in Florida, five in Osceola County (Kissimmee, St. Cloud and Poinciana) and one fice located in Orlando. Three the branches are located in moderate-income census tracts and the other three are located in middle-income tracts. For economic reasons, the Ocoee branch located in Orange County was closed on March 28, The branch was located in an upper-income census tract. The bank fers many services to its customers, including drive-up facilities and automated teller machine (ATM) access at all locations, debit card services and 24-hour internet and telephone banking. In addition, CSBCFL provides low- to no-cost checking accounts. While the bank fers home mortgage and consumer lending products, its strategic focus is on commercial lending, which represents 73%, or $147 million the loan portfolio. As March 31, 2009, the bank had total assets $282 million with net loans accounting for 71% total assets. There are no financial, legal or other impediments that would prevent the bank from meeting the credit needs the community. CSBCFL s last Community Reinvestment Act (CRA) evaluation was in November 2004, where they were given a Satisfactory rating for meeting community credit needs. DESCRIPTION OF ASSESSMENT AREA The assessment area (AA) for this review consists 66 census tracts that include all Osceola County and a portion Orange County, both which are part the Orlando-Kissimmee, Florida Metropolitan Statistical Area (MSA #36740). Osceola County is the sixth largest county in Florida and is the fastest growing area in central Florida. The largest city in the AA and Osceola County is Kissimmee which is located in the South Orlando metro area. Kissimmee is in the middle central Florida and is considered the gateway city to Disney World and other world famous attractions. From a business perspective, Kissimmee is centrally located where the Interstate 4 corridor crosses the Florida Turnpike. Major industries include tourism, trade, education and health and social services. Economically, Osceola County has experienced slowdown in job growth during 2008 and yearto-date 2009 and, based on the Bureau Labor Statistics, the unemployment rate was 10.7 percent in February As a result the national economy being in decline, the economy in the AA was negatively impacted by a slowdown in the tourist industry and residential and commercial construction. Most job losses in 2008 were in the construction, pressional and business services and trade, transportation and utilities industries. However, the MSA showed job growth in education and health along with leisure and hospitality sectors. The assessment area contains 20 moderate-income tracts, 33 middle-income tracts and 13 upperincome tracts. There are no low-income census tracts. The census tract designations are based 2
4 on the 2000 U.S. Census median family income $47,851 for the Orlando-Kissimmee MSA. The Department Housing and Urban Development (HUD) estimates the 2008 median family income at $59,200 for the MSA. The assessment area has a total population 375,332 based on the 2000 Census. The assessment area meets the legal requirements the Act and does not arbitrarily exclude low- or moderate-income census tracts. There is a significant amount banking competition in Osceola County, with 18 banks operating 66 fices. According to FDIC deposit market share data as June 30, 2008, major competitors in the county include Bank America, N.A, SunTrust Bank, Wachovia Bank, N.A., Colonial Bank and Washington Mutual Bank. Contact by the OCC with two locally based not-for-prit organizations stated the performance local financial institutions were satisfactory; however, banks should continue to participate in affordable housing and small business lending programs. Specifically, banks can assist in this effort by providing borrower financing, funding construction and permanent financing for rental properties, providing operating grants and volunteering time to financial and homebuyer counseling programs. SCOPE OF EXAMINATION CSBCFL s primary focus is small business lending in the AA. As March 31, 2009, business lending represented 73% all loans in the portfolio. As such, this conclusion was based on an analysis a random sample business loans originated during January 1, 2007 through March 31, CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA Lending Test Loan-to-Deposit Ratio - Meets the Standard for Satisfactory Performance CSBCFL s average loan-to-deposit (LTD) ratio is reasonable at 75% and is comparable to peer averages. The average loan-to-deposit ratio was calculated and averaged for each quarter since the last CRA examination in November 2004 through December 31, We compared the bank s average LTD ratio to all banks with total assets less than $250 million and located in the counties where the bank has fices. The average LTD ratio for the past 16 quarters for CSBCFL was 75% which is comparable to the eight peer banks average LTD ratio 83% for the same time period. Lending in Assessment Area - Exceeds the Standard for Satisfactory Performance A substantial majority business lending occurs in the assessment area. This conclusion is based on analysis a random sample 55 business loans originated during January 1, 2007 through March 31, As detailed in the table below, 89% by number and 80% by dollar amount sampled loans made during our evaluation period were within CSBCFL s assessment area. Lending in the Assessment Area 3
5 Dollars (000's) Type Inside Outside Total Inside Outside Total Loan # % # % $ % $ % Commercial 49 89% 6 11% 55 $17,401 80% $4,324 20% $21,725 Lending to Different Sizes - Exceeds the Standard for Satisfactory Performance CSBCFL s lending activities show excellent penetration among businesses different sizes. Our sample, as noted above, was based on the 55 business loans made in the assessment area during the evaluation period. The following charts show a breakdown those loans according to business and loan size for the assessment area. Borrower Distribution to in the Assessment Area Business Revenues (or Sales) <= $1,000,000 > $1,000,000 Revenue Unavailable Total % AA 66.00% 2.00% 32.00% % % Bank in AA by # 75.50% 24.50% 0.00% % % Bank in AA by $ 71.00% 29.00% 0.00% % Borrower Distribution to in the Assessment Area $ Volume Loan Size loans Percent # (000 s) % $s $0-$100, % $ % $100,001-$250, % $2, % $250,001-$500, % $4, % $500,001-$1,000, % $4, % $1,000,001-$2,500, % $5, % Total % $17, % As depicted in the tables above, the percentage loans to small businesses exceeds the percent such businesses operating in the AA. Based on our sample, CSBCFL originated 75.50% total number loans and 71.00% total dollar volume loans to small businesses (those with total revenues $1 million or less). In comparison, businesses in the assessment area that reported revenues (32% did not report revenues), 66% are considered small businesses. Additionally, the analysis noted 28 loans, or 57% all AA business loans sampled, had original amounts $250 thousand or less. Likewise, 40 loans, or 82% all AA business loans sampled, had original amounts $500 thousand or less. 4
6 Geographic Distribution - Exceeds the Standard for Satisfactory Performance The geographic distribution lending is excellent. Our analysis was based on the same sample business loans originated during the evaluation period. The following table reflects the distribution sampled loans within the bank s assessment area by income designation census tract. Geographic Distribution Business in the Assessment Area Census Tract Income Level Low Moderate Middle Upper % AA % % AA % % AA % % AA % % Total 0.00% 0.00% 28.00% 30.61% 52.00% 65.31% % There are no low-income tracts but in moderate-income census tracts, the percentage loans made exceeds the percent businesses located there. The business loan sample shows the bank extended 30.61% its business loans to businesses that reported revenues and are located in moderate-income census tracts. By comparison, these census tracts account for 28% all businesses within the assessment area. Likewise, lending to middle-income census tracts also shows a similar pattern distribution as shown in the chart above. Responses to Complaints - There were no CRA related complaints received by the bank or our fice during the period review. Fair Lending or Other Illegal Credit Practices Review We found no evidence illegal discrimination or other illegal credit practices. 5
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