§__.21(b)(5) Consideration of Similarly Situated Lenders
§__.21(b)(5) – 2 Q: How will examiners consider the performance of similarly situated lenders? A2. The performance context section of the regulation permits the performance of similarly situated lenders to be considered, for example, as one of a number of considerations in evaluating the geographic distribution of an institution’s loans to low-, moderate-, middle-, and upper-income geographies….
§__.21(f) Minority- and Women-Owned Institutions & Low-Income Credit Unions
§__.21(f) – 1 Q: The CRA provides that, in assessing the CRA performance of nonminority- and non-women-owned (majority-owned) financial institutions, examiners may consider as a factor capital investments, loan participations, and other venues undertaken by the institutions in cooperation with minority- or women-owned financial institutions and low-income credit unions (MWLI), provided that these activities help meet…
§__.22(a) Scope of Lending Test
§__.22(a) – 1 Q: Are there any types of lending activities that help meet the credit needs of an institution’s assessment area(s) and that may warrant favorable consideration as activities that are responsive to the needs of the institution’s assessment area(s)? A1. Credit needs vary from community to community. However, there are some lending activities that are…
§__.22(a)(i) Mortgage Loan Evaluation for non-HMDA Reporters
§__.22(a)(1) – 1 Q: If a large retail institution is not required to collect and report home mortgage data under the HMDA, will the Agencies still evaluate the institution’s home mortgage lending performance? A1. Yes. The Agencies will sample the institution’s home mortgage loan files in order to assess its performance under the lending test criteria. …
§__.22(a)(1) CRA Consideration of Consumer Loans
§__.22(a)(1) – 2 Q: When will examiners consider consumer loans as part of an institution’s CRA evaluation? A2. Consumer loans will be evaluated if the institution so elects and has collected and maintained the data; an institution that elects not to have its consumer loans evaluated will not be viewed less favorably by examiners than one that…
§__.22(a)(2) CRA Evaluation of Loan Commitments
§__.22(a)(2) – 1 Q: How are lending commitments (such as letters of credit) evaluated under the regulation? A1. The Agencies consider lending commitments (such as letters of credit) only at the option of the institution, regardless of examination type. Commitments must be legally binding between an institution and a borrower in order to be considered Information about lending…
§__.22(a)(2) Review of Loan Application Data
§__.22(a)(2) – 2 Q: Will examiners review application data as part of the lending test? A2. Application activity is not a performance criterion of the lending test. However, examiners may consider this information in the performance context analysis because this information may give examiners insight on, for example, the demand for loans. Source: Interagency Questions & Answers Regarding…
§__.22(a)(2) CRA Consideration for Purchased Loan Modifications and Extensions
§__.22(a)(2) – 3 Q: May a financial institutions receive consideration under CRA for home mortgage loan modification, extension, and consolidation agreements (MECA), in which it obtains home mortgage loans from other institutions without actually purchasing or refinancing the home mortgage loans, as those terms have been interpreted under CRA and HMDA, as implemented by 12 CFR…
§__.22(a)(2) Other Loan Data Examples
§__.22(a)(2) – 4 Q: In addition to MECAs (Modifications, Extensions, and Consolidation Agreements), what are other examples of “other loan data”? A4. Other loan data include, for example, loans funded for sale to the secondary markets that an institution has not reported under HMDA; unfunded loan commitments and letters of credit; commercial and consumer leases; loans secured…
§__.22(a)(2) CRA Consideration for Fully Guaranteed Loans
§__.22(a)(2) – 5 Q: Do institutions receive consideration for originating or purchasing loans that are fully guaranteed? A5. Yes. For all examination types, examiners evaluate an institution’s record of helping to meet the credit needs of its assessment area(s) through the origination or purchase of specified types of loans. Examiners do not take into account whether or…