CRA COVID FAQ 16: Community Development Eligiblity of Paycheck Protection Program (PPP) Loans in Low- or Moderate-Income, Distressed or Underserved Geographies
Question 16 Are PPP loans over $1 million that are also in low- or moderate-income geographies or in distressed or underserved nonmetropolitan middle-income geographies automatically considered to be community development activities? (new FAQ added March 8, 2021) Response 16 Yes, a PPP loan greater than $1 million in one of these geographies will be considered…
CRA COVID FAQ 17: CRA Community Service Consideration of Fee Waivers and Other Account Accommodations
Question 17 Due to the economic distress caused by the COVID-19 pandemic, some banks have been: Will CRA community development service credit be given for these types of actions during the pandemic? How should banks document these activities and the number of customers served by them? (new FAQ added March 8, 2021) Response 17 The Joint…
CRA COVID FAQ 18: CRA Consideration for Services Provided Virtually by Bank Employees
Question 18 Considering the challenge of providing in-person community development services during the COVID-19 pandemic, how will such services provided virtually by bank representatives be considered for CRA purposes? (new FAQ added March 8, 2021) Response 18 Historically, for CRA purposes, bank representatives have primarily provided community development services in-person. However, the agencies recognize that…
Large Institutions | Examination Scope
For institutions (interstate and intrastate) with more than one assessment area, identify assessment areas for a full-scope review. A full-scope review is accomplished when examiners complete all of the procedures for an assessment area. For interstate institutions, a minimum of one assessment area from each state, and a minimum of one assessment area from each…
Large Institutions | Performance Context
1. Review standardized worksheets and other agency information sources to obtain relevant demographic, economic, and loan data, to the extent available, for each assessment area under review. Compare the data to similar data for the MSA/MD, county, or state to determine how any similarities or differences will help in evaluating lending, investment, and service opportunities…
Large Institutions | Assessment Area
1. Review the institution’s stated assessment area(s) to ensure that it: a. Consists of one or more MSAs/MDs or contiguous political subdivisions (i.e., counties, cities, or towns); b. Includes the geographies where the institution has its main office, branches, and deposittaking (Automated Teller Machines) ATMs, as well as the surrounding geographies in which the institution…
Large Institutions | Lending Test
1. Identify the institution’s loans to be evaluated by reviewing: a. The most recent HMDA and CRA Disclosure Statements, the interim HMDA Loan Application Register (LAR), and any interim CRA loan data collected by the institution; b. A sample of consumer loans if consumer lending represents a substantial majority of the institution’s business so that…
Large Institutions | Investment Test
1. Identify qualified investments by reviewing the institution’s investment portfolio, and at the institution’s option, its affiliate’s investment portfolio. As necessary, obtain a prospectus, or other information that describes the investment(s) and the geographic area(s) or population(s) served. This review should encompass qualified investments, including investments in a broader statewide or regional area and in…
Large Institutions | Service Test | Retail Banking Services
1. Determine from information available in the institution’s public file: a. The distribution of the institution’s branches among low-, moderate-, middle-, and upperincome geographies in the institution’s assessment area(s); and b. Banking services, including hours of operation and available loan and deposit products. 2. Obtain the institution’s explanation for any material differences in the hours…
Large Institutions | Service Test | Community Development Services
For items #1 – #5, see the related article “Large Institutions | Service Test | Community Development Services| 6. Identify the institution’s community development services including, at the institution’s option, services through affiliates. Hold discussions with management and review available materials. Determine: a. Whether services have been considered under the lending or investments tests:…