CRA
3 tests for larger banks under CRA
Lending, investment and service
What is the best method for a large bank to use in monitoring its CRA performance?
Perform a geographic analysis of lending levels and dispersion of loans
CRA Asset-Size Thresholds
Thresholds Small Bank: < $1.252 two calendar years Intermediate Bank: at least $313 million $1.252 billion Covered under CRA
What test is required for a wholesale or limited purpose bank under CRA?
community development test
Small bank CRA test
lending test (loan to deposit ratio, credit extended inside and outside of the AA, geographic distribution, response to written complaints
Intermediate bank CRA test
lending test and community development test
What must a bank do with a signed letter criticizing its performance meeting the credit needs of the community?
retain it in the CRA public file no other specific action
Not covered under CRA
special purpose banks that do not perform commercial or consumer banking services or only engage in cash management, disbursement services, trust companies or clearing agents
What is a requirement of CRA?
to delineate the bank's assessment are to collect loan data to report small business loan data