§__.22(d) Evaluation of Loans Made by Consortia or Third Parties
§__.22(d) – 2 Q: Regardless of examination types, how will examiners evaluate loans made by consortia or third parties? A2. Loans originated or purchased by consortia in which an institution participates or by third parties in which an institution invests will be considered only if they qualify as community development loans and will be considered only under…
§__.22(d) Community Development Loans Held in Common
§__.22(d) – 3 Q: In some circumstances, an institution may invest in a third party, such as a community development bank, that is also an insured depository institution and is thus subject to CRA requirements. If the investing institutions requests its supervisory Agency to consider its pro rata share of community development loans made by the…
§__.23(a) Indirect Investment in Community Development Fund
§__.23(a) – 1 Q: May an institution, regardless of examination type, receive consideration under the CRA regulations if it invests indirectly through a fund, the purpose of which is community development, as that is defined in the CRA regulations? A1. Yes, the direct or indirect nature of the qualified investment does not affect whether an institution will…
§__.23(a) Documentation of Assessment Area Impact from Nationwide Fund Investments
§__.23(a) – 2 Q: In order to receive CRA consideration, what information may an institution provide that would demonstrate that an investment in a nationwide fund with a primary purpose of community development will directly or indirectly benefit one or more of the institution’s assessment area(s) or a broader statewide or regional area that includes the…
§__.23(b) CRA Consideration Under Multiple Tests
§__.23(b) – 1 Q: Even though the regulations state that an activity that is considered under the lending or service tests cannot also be considered under the investment test, may parts of an activity be considered under one test and other parts be considered under another test? A1. Yes, in some instances the nature of an activity…
§__.23(b) Mortgage-Backed Securities Comprised of HMDA-Reported Loans
§__.23(b) – 2 Q: If home mortgage loans to low- and moderate-income borrowers have been considered under an institution’s lending test, may the institution that originated or purchased them also receive consideration under the investment these if it subsequently purchases mortgage-backed securities that are primarily or exclusively backed by such loans? A2. No. Because the institution received…
§__.23(e) Distinguishing Qualified Investments Based on Actual Community Development Purpose
§__.23(e) – 1 Q: When applying the four performance criteria of 12 CFR__.23(e), may an examiner distinguish among qualified investments based on how much of the investment actually supports the underlying community development purpose? A1. Yes. By applying all the criteria, a qualified investment of a lower dollar amount may be weighed more heavily under the investment…
§__.23(e) CRA Evaluation of Qualified Investment in a Fund
§__.23(e) – 2 Q: How do examiners evaluate an institution’s qualified investment in a fund, the primary purpose of which is community development, as defined in the CRA regulations? A2. When evaluating qualified investments that benefit an institution’s assessment area(s) or a broader statewide or regional area that includes its assessment area(s), examiners will look at the…
§__.24(a) Evaluating Retail Banking Services and Community Development Services
§__.24(a) – 1 Q: How do examiners evaluate retail banking services and community development services under the large institution service test? A1. Retail banking services and community development services are the two components of the service test and are both important in evaluating a large institution’s performance. In evaluating retail banking services, examiners consider the availability and effectiveness…
§__.24(d) Availability and Effective of Systems for Delivering Retail Banking Services
§__.24(d) – 1 Q: How do examiners evaluate the availability and effectiveness of an institution’s systems for delivery retail banking services? A1. Convenient access to full service branches within a community is an important factor in determining the availability of credit and non-credit services. Therefore, the service test performance standards place primary emphasis on full service branches while still considering alternative…