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