OCC Clarifies Supervisory Policy, Processes for CRA Performance Evaluations

On Friday, June 15, 2018, the OCC issued a bulletin informing national banks, federal savings associations, and federal branches and agencies (collectively, banks) about clarifications to OCC supervisory policies and processes regarding how examiners evaluate and communicate bank performance under the CRA. The OCC has clarified and simplified these policies and processes to promote the consistency and effectiveness of CRA performance evaluations. These supervisory policies and processes apply to each bank CRA evaluation.

 

Highlights

 

The CRA supervisory policy addresses the following areas for all CRA evaluations. These policy clarifications, which are effective immediately, address

  • implementation of full-scope and limited-scope reviews;
  • consideration of activities that promote economic development;
  • use of demographic, aggregate, and market share data;
  • evaluation of the borrower distribution of loans outside bank assessment areas (AA);
  • evaluation frequency and timing;
  • the CRA performance evaluation period; and
  • evaluation of home mortgage loans.

 

Clarifications on standard processes related to CRA evaluations were communicated to examiners and became effective on May 2, 2017. These clarifications address

  • the type of information considered and presented in the written performance evaluation (PE) and the process for sharing CRA evaluation data and ratings with OCC-supervised banks.
  • factors considered when evaluating bank performance under the small- and large-bank lending tests.
  • branch distribution when concluding on the availability and effectiveness of bank systems for delivering retail banking services.
  • internal and external performance context factors when concluding on performance.
  • consideration of CRA plans imposed as conditions of approval of corporate applications in the evaluation process.