OCC Issues Bulletin Outlining How Examiners Assess CRA Performance

While its efforts to modernize Community Reinvestment Act regulations proceed along a separate track, the OCC today issued a bulletin to clarify current OCC policies and processes for assessing banks’ CRA performance. Transitional procedures are being implemented,” the agency said in issuing the bulletin. “If banks with CRA evaluations in progress believe these policies will create a burden during an ongoing evaluation, they should raise this concern with their examiners.”

The bulletin covers policy clarifications that take effect immediately and address the implementation of full-scope and limited-scope reviews; consideration of activities that promote economic development; use of demographic, aggregate, and market share data; evaluation of the borrower distribution of loans outside bank assessment areas; evaluation frequency and timing; the CRA performance evaluation period; and evaluation of home mortgage loans.

It also covers clarifications on standard processes related to CRA evaluations that were communicated to examiners and took effect on May 2, 2017. These clarifications address the type of information considered in a written performance evaluation, the process for sharing CRA evaluation data and ratings with OCC-supervised banks, factors considered when evaluating bank performance under tests for both small and large banks’ lending, branch distribution, internal and external performance context factors and the consideration of CRA plans imposed as conditions of approval of applications. For more information, contact ABA’s Krista Shonk.