Breaking Down the CRA Exam! Josh Silver, Vice President of Research and Policy, NCRC March 22, 2013

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1 Breaking Down the CRA Exam! Josh Silver, Vice President of Research and Policy, NCRC March 22, 2013

2 Federal Agencies Conducting CRA Exams Federal Reserve Board Federal Deposit Insurance Corporation Office of Thrift Supervision (ceased operations but still has exams on webpbage) Office of the Comptroller of the Currency Federal Financial Institutions Examination Council

3 CRA Exams: Frequency & Ratings CRA exams scrutinize banks about once every two years for banks or thrifts with assets > $250 million. Once every four or five years for small banks with assets < $250 million Banks and thrifts receive one of four grades: Outstanding, Satisfactory, Needs-to-Improve, and Substantial Non- Compliance Possible Low- and High-Satisfactory Ratings for component tests and geographical areas

4 How to Find Out About CRA Exams! Every 3 months, the federal agencies publish a schedule of CRA exams. Obtain the schedule from the federal agency websites or from NCRC. Locate regional office of agency conducting CRA exam NCRC can help

5 Small Banks! Less than $250 million Lending test only Five factors including responses to public complaints No reporting of CRA data on small business or community development lending

6 Intermediate Small Banks! Banks and thrifts with assets between $250 million and $1 billion (annual inflation adjustment to asset range). Lending and community development (CD) test. Not required to report CRA data on small business or farm lending

7 Large Bank CRA Exams! Large bank exam banks with assets above $1 billion Lending, investment, and service test. Large banks must report CRA small business, farm and CD loan data.

8 Exams for Wholesale and Limited Purpose Banks! Community Development Test Strategic Plan in lieu of regular exam, mostly used by non-retail banks

9 Parameters for CRA Exams! Assessment Areas Make sure do not exclude LMI areas Affiliates Bank can choose to include/exclude affiliates Performance context make sure examiners adequately asses needs; don t excuse poor performance on poverty rates, or lack of investment opportunities

10 Performance Measures! Do the measures fairly and rigorously measure performance? Lending Test Bankʼs percent of loans to LMI compared to all lenders, as a group. Consistently above or below? OCC Market share analysis Bankʼs share of loans in LMI market compared to bankʼs overall market share Investment Test investments to Tier 1 capital or assets; in addition to quantitative measures, are investments innovative or responsive Service Test any quantitative information on number of bank accounts; percent of branches in LMI neighborhoods compared to peers or demographics?

11 Words Used by Examiners! Excellent - corresponds to Outstanding Good corresponds to High Satisfactory Adequate corresponds Low Satisfactory Poor corresponds to Needs to Improve Very poor corresponds to Substantial Noncompliance

12 Why Being Active on CRA Exams is Important! CRA has leveraged trillions of dollars in loans, investments, and services since 1977; studies have demonstrated positive impact in increasing safe and sound loans and investments: Federal Reserve, Harvard University, NCRC Comments on CRA exams can influence ratings overall or in one or more geographical areas or component tests; lower ratings on any of the exam components are motivation for banks to improve Merger application process more likely bank will make reforms or make a specific pledge if members of public comment; $180 billion Capital One pledge, for example. On-going discussions with bank CRA officials in your community

13 To follow up with the speaker: Josh Silver, Vice President of Research and Policy National Community Reinvestment Coalition or Presentations will be available at by March 29, 2013

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