Community Reinvestment Act: Interagency Examination Procedures

On July 19, 2005, the Office of the Comptroller of the Currency (OCC), along with the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (the agencies) revised their Community Reinvestment Act (CRA) regulations.¹ The revisions to the CRA regulations are effective September 1, 2005.

Among the revisions to the regulations is a new test, the community development test, for intermediate small banks. Intermediate small banks have total assets of at least $250 million as of December 31 of both of the prior two calendar years and less than $1 billion as of December 31 of either of the prior two calendar years. These banks will be examined under the existing small bank lending test and the new community development test for intermediate small banks. The agencies have adopted the attached interagency examination procedures for intermediate small banks. The CRA regulation continues, however, to allow small institutions, including intermediate small institutions, to opt for examination as a large bank under the lending, investment, and services tests.

Intermediate small banks are not required to collect and report CRA loan data for small business, small farm, and community development loans. These banks may stop collecting CRA loan data on September 1, 2005. Any CRA loan data collected prior to September 1, 2005, would not be reported to the agencies. Banks may retain data collected in 2005, at their option, for internal tracking, analysis, or planning purposes. As a result, to evaluate the distribution of loans, examiners will review loan files, bank reports, and any other bank information or analyses. In addition, to evaluate community development loans, qualified investments, and community development services, examiners will review any information banks may provide, including the results of any assessment of community development needs and opportunities, and performance context information obtained by examiners from community, government, civic, and other sources.

The OCC plans to incorporate these procedures in an updated booklet in the Comptroller’s Handbook. Until the revised booklet is issued, examiners will use the attached procedures. Questions about the CRA regulations and these examination procedures may be directed to your supervisory office or Karen Tucker, national bank examiner in the Compliance Policy Department, at (202) 649-5470. Additional information about the revised CRA regulation can be found in OCC Bulletin 2005-28.

Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

Related Links

• Intermediate Small Bank CRA Examination Procedures