§__.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…
§__.24(d) Individual Development Accounts
§__.24(d) – 2 Q: How do examiners evaluate an institution’s activities in connection with Individual Development Accounts (IDA)? A2. Although there is no standard IDA program, IDAs typically are deposit accounts targeted to low- and moderate-income families that are designed to help them accumulate savings for education or job-training, down-payment and closing costs on a new home, or start-up…
§__.24(d)(3) Alternative Systems for Delivering Retail Banking Services
§__.24(d)(3) – 1 Q: How do examiners evaluate alternative systems for delivering retail banking services? A1. There are a number of alternative systems used by financial institutions to deliver retail banking services to customers. Non-branch delivery systems, such as ATMs, online and mobile banking, and other means by which institutions provide services to their customers evolve over time. No matter the…
§__.24(d)(3) Debit Cards as Alternative Delivery System
§__.24(d)(3) – 2 Q: Are debit cards considered under the service test as an alternative delivery system? A2. By themselves, no. However, if debit cards are a part of a larger combination of products, such as a comprehensive electronic banking service, that allows an institution to deliver needed services to low- and moderate-income areas and individuals in its…
§__.24(d)(4) Evaluation of Services and Tailoring to Meet Community Needs
§__.24(d)(4) – 1 Q: How do examiners evaluate the range of services provided in low-, moderate-, middle-, and upper-income geographies and the degree to which those services are tailored to meet the needs of those geographies? A1. Examiners review both information from the institution’s public file and other information provided related to the range of services offered…