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: and b. If provided by affiliates of the institution, services are not claimed by other affiliated institutions.
7. Evaluate performance using information obtained in the performance context procedures, especially with regard to community needs and institutional capacity. Determine:
a. The extent of community development services provided in:
i. The institution’s assessment area(s); or
ii. The broader statewide or regional area that includes the assessment area(s) that support organizations or activities with a purpose, mandate, or function that includes serving the geographies or individuals located within the institution’s assessment area(s).
b. Their innovativeness, including whether they serve low- or moderate-income customers in new ways or serve groups of customers not previously served; and
c. The degree to which they serve low- or moderate-income areas or individuals and their responsiveness to available opportunities for community development services.
8. If the institution has been responsive to community development needs and opportunities in its assessment area(s) based on the analysis in step number 7, consider:
a. The extent of community development services in the broader statewide or regional area that includes the assessment area(s), but:
i. Will not benefit the assessment area(s); and
ii. Do not support organizations or activities with a purpose, mandate, or function that includes serving geographies or individuals located within the institution’s assessment area(s).
b. The extent to which these services enhance the institution’s performance. Note: Refer to the appendix for additional guidance on addressing activities at the state or multistate MSA, or institution level.
9. Discuss with management the preliminary findings.
10. Summarize conclusions about the institution’s system for delivering retail banking and community development services, considering:
a. The distribution of branches among low-, moderate-, middle-, and upper-income geographies;
b. The institution’s record of opening and closing branches, particularly branches located in low- or moderate-income geographies or primarily serving low- or moderate-income individuals;
c. The availability and effectiveness of alternative systems for delivering retail banking services;
d. The extent to which the institution provides community development services;
e. The innovativeness and responsiveness of community development services; and f. The range and accessibility of services provided in low-, moderate-, middle-, and upperincome geographies.
11. Prepare comments for the performance evaluation and the Compliance examination report. Refer to the appendix for guidance on addressing community development activities in the performance evaluation.
SOURCE: Large Institution CRA Examination Procedures | OCC, FRB, and FDIC | April 2014