Community Reinvestment Act; Interagency Questions and Answers Regarding Community Reinvestment; Notice, 498-542 [E8-31116]
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
[Docket ID OCC–2008–0027]
FEDERAL RESERVE SYSTEM
[Docket No. OP–1349]
FEDERAL DEPOSIT INSURANCE
CORPORATION
DEPARTMENT OF THE TREASURY
Office of Thrift Supervision
[Docket ID OTS–2008–0022]
RIN 3064–AC97
Community Reinvestment Act;
Interagency Questions and Answers
Regarding Community Reinvestment;
Notice
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AGENCIES: Office of the Comptroller of
the Currency, Treasury (OCC); Board of
Governors of the Federal Reserve
System (Board); Federal Deposit
Insurance Corporation (FDIC); Office of
Thrift Supervision, Treasury (OTS).
ACTION: Notice and request for comment.
SUMMARY: The OCC, Board, FDIC, and
OTS (the agencies) are adopting as final
the Interagency Questions and Answers
Regarding Community Reinvestment
(Questions and Answers) that were
proposed on July 11, 2007. In response
to comments received, the agencies
clarified several of the new and revised
questions and answers that were
proposed and are withdrawing the
proposed revisions to an existing
question and answer. Also, in response
to comments we received, the agencies
are proposing a new question and
answer that would provide examples of
how an institution can determine that
community services it provides are
targeted to low- and moderate-income
individuals. The agencies are also
proposing to revise two existing
questions and answers to allow pro rata
consideration in certain circumstances
for an activity that provides affordable
housing targeted to low-or moderateincome individuals. The agencies invite
public comment on these proposed new
and revised questions and answers.
DATES: Effective date of amended
Interagency Questions and Answers
Regarding Community Reinvestment:
January 6, 2009. We request that
comments on the proposed questions
and answers be submitted on or before:
March 9, 2009.
ADDRESSES: Comments should be
directed to:
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OCC: Because paper mail in the
Washington, DC area and at the
Agencies is subject to delay,
commenters are encouraged to submit
comments by e-mail, if possible. Please
use the title ‘‘Community Reinvestment
Act; Interagency Questions and Answers
Regarding Community Reinvestment’’ to
facilitate the organization and
distribution of the comments. You may
submit comments by any of the
following methods:
• E-mail:
regs.comments@occ.treas.gov.
• Mail: Office of the Comptroller of
the Currency, 250 E Street, SW., Mail
Stop 1–5, Washington, DC 20219.
• Fax: (202) 874–4448.
• Hand Delivery/Courier: 250 E
Street, SW., Attn.: Public Information
Room, Mail Stop 1–5, Washington, DC
20219.
Instructions: You must include
‘‘OCC’’ as the agency name and ‘‘Docket
ID OCC–2008–0027’’ in your comment.
In general, OCC will enter all comments
received into the docket without
change, including any business or
personal information that you provide
such as name and address information,
e-mail addresses, or phone numbers.
Comments received, including
attachments and other supporting
materials, are part of the public record
and subject to public disclosure. Do not
enclose any information in your
comment or supporting materials that
you consider confidential or
inappropriate for public disclosure.
You may review comments and other
related materials that pertain to this
notice by any of the following methods:
• Viewing Comments Personally: You
may personally inspect and photocopy
comments at the OCC’s Public
Information Room, 250 E Street, SW.,
Washington, DC. For security reasons,
the OCC requires that visitors make an
appointment to inspect comments. You
may do so by calling (202) 874–5043.
Upon arrival, visitors will be required to
present valid government-issued photo
identification and submit to security
screening in order to inspect and
photocopy comments.
• Docket: You may also view or
request available background
documents and project summaries using
the methods described above.
Board: You may submit comments,
identified by Docket No. OP–1349, by
any of the following methods:
• Agency Web Site: https://
www.federalreserve.gov. Follow the
instructions for submitting comments at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
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• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
regs.comments@federalreserve.gov.
Include docket number in the subject
line of the message.
• Fax: 202–452–3819 or 202–452–
3102.
• Mail: Jennifer J. Johnson, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue, NW., Washington,
DC 20551.
All public comments are available from
the Board’s Web site at https://
www.federalreserve.gov/generalinfo/
foia/ProposedRegs.cfm as submitted,
unless modified for technical reasons.
Accordingly, your comments will not be
edited to remove any identifying or
contact information. Public comments
may also be viewed electronically or in
paper in Room MP–500 of the Board’s
Martin Building (20th and C Streets,
NW.) between 9 a.m. and 5 p.m. on
weekdays.
FDIC: You may submit comments,
identified by RIN number 3064–AC97
by any of the following methods:
• Agency Web site: https://
www.fdic.gov/regulations/laws/federal/
propose.html. Follow instructions for
submitting comments on the Agency
Web Site.
• E-mail: Comments@FDIC.gov.
Include the RIN number in the subject
line of the message.
• Mail: Robert E. Feldman, Executive
Secretary, Attention: Comments, Federal
Deposit Insurance Corporation, 550 17th
Street, NW., Washington, DC 20429.
• Hand Delivery/Courier: Guard
station at the rear of the 550 17th Street
Building (located on F Street) on
business days between 7 a.m. and 5 p.m.
Instructions: All submissions received
must include the agency name and RIN
number. All comments received will be
posted without change to https://
www.fdic.gov/regulations/laws/federal/
propose.html including any personal
information provided.
OTS: You may submit comments,
identified by OTS–2008–0022, by any of
the following methods:
• E-mail:
regs.comments@ots.treas.gov. Please
include ID OTS–2008–0022 in the
subject line of the message and include
your name and telephone number in the
message.
• Fax: (202) 906–6518.
• Mail: Regulation Comments, Chief
Counsel’s Office, Office of Thrift
Supervision, 1700 G Street, NW.,
Washington, DC 20552, Attention: OTS–
2008–0022.
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• Hand Delivery/Courier: Guard’s
Desk, East Lobby Entrance, 1700 G
Street, NW., from 9 a.m. to 4 p.m. on
business days, Attention: Regulation
Comments, Chief Counsel’s Office,
Attention: OTS–2008–0022.
Instructions: All submissions received
must include the agency name and
docket number for this rulemaking. All
comments received will be entered into
the docket and posted on
Regulations.gov without change,
including any personal information
provided. Comments, including
attachments and other supporting
materials received are part of the public
record and subject to public disclosure.
Do not enclose any information in your
comment or supporting materials that
you consider confidential or
inappropriate for public disclosure.
Viewing Comments Electronically:
OTS will post comments on the OTS
Internet Site at https://www.ots.treas.gov/
pagehtml.cfm?catNumber=67&an=1.
Viewing Comments On-Site: You may
inspect comments at the Public Reading
Room, 1700 G Street, NW., by
appointment. To make an appointment
for access, call (202) 906–5922, send an
e-mail to public.info@ots.treas.gov, or
send a facsimile transmission to (202)
906–6518. (Prior notice identifying the
materials you will be requesting will
assist us in serving you.) We schedule
appointments on business days between
10 a.m. and 4 p.m. In most cases,
appointments will be available the next
business day following the date we
receive a request.
FOR FURTHER INFORMATION CONTACT:
OCC: Karen Tucker, National Bank
Examiner, Compliance Policy Division,
(202) 874–4428; or Margaret Hesse,
Special Counsel, Community and
Consumer Law Division, (202) 874–
5750, Office of the Comptroller of the
Currency, 250 E Street, SW.,
Washington, DC 20219.
Board: Anjanette M. Kichline, Senior
Supervisory Consumer Financial
Services Analyst, (202) 785–6054; or
Brent Lattin, Attorney, (202) 452–3667,
Division of Consumer and Community
Affairs, Board of Governors of the
Federal Reserve System, 20th Street and
Constitution Avenue, NW., Washington,
DC 20551.
FDIC: Deirdre Foley, Senior Policy
Analyst, Division of Supervision and
Consumer Protection, Compliance
Policy Branch, (202) 898–6612; or Susan
van den Toorn, Counsel, Legal Division,
(202) 898–8707, Federal Deposit
Insurance Corporation, 550 17th Street,
NW., Washington, DC 20429.
OTS: Celeste Anderson, Senior Project
Manager, Compliance and Consumer
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Protection, (202) 906–7990; or Richard
Bennett, Senior Compliance Counsel,
Regulations and Legislation Division,
(202) 906–7409, Office of Thrift
Supervision, 1700 G Street, NW.,
Washington, DC 20552.
SUPPLEMENTARY INFORMATION:
Background
The OCC, Board, FDIC, and OTS
implement the Community
Reinvestment Act (CRA) (12 U.S.C. 2901
et seq.) through their CRA regulations.
See 12 CFR parts 25, 228, 345, and 563e.
The OCC, Board, and FDIC revised their
CRA regulations in a joint final rule
published on August 2, 2005 (70 FR
44256) (2005 joint final rule). OTS did
not join the agencies in adopting the
August 2005 joint final rule; OTS
published separate final rules on August
18, 2004 (69 FR 51155), March 2, 2005
(70 FR 10023), April 12, 2006 (71 FR
18614), and March 22, 2007 (72 FR
13429). On July 1, 2007, the March 2007
revisions to OTS’s CRA regulation
became effective, making OTS’s CRA
regulation substantially the same as the
CRA regulations of the OCC, Board, and
FDIC.
The agencies’ regulations are
interpreted primarily through the
‘‘Interagency Questions and Answers
Regarding Community Reinvestment’’
(Questions and Answers), which
provide guidance for use by agency
personnel, financial institutions, and
the public. The Questions and Answers
were first published under the auspices
of the Federal Financial Institution
Examination Council (FFIEC) in 1996
(61 FR 54647), and were revised on July
12, 2001 (2001 Questions and Answers)
(66 FR 36620).
Subsequent to the adoption of the
2005 joint final rule, the OCC, Board,
and FDIC, after notice and public
comment, published new guidance in
the form of questions and answers on
March 10, 2006 (71 FR 12424) (2006
Questions and Answers). The 2006
Questions and Answers addressed
primarily matters related to the 2005
joint final rule. On September 5, 2006,
after notice and public comment, OTS
published new guidance in the form of
questions and answers pertaining to the
revised definition of ‘‘community
development’’ and certain other
provisions of the CRA rule common to
all four agencies (OTS’s September 2006
Questions and Answers). 71 FR 52375.
On July 11, 2007, the agencies
published for comment proposed
guidance, which updated and revised
the 2001 Questions and Answers and
combined the 2006 Questions and
Answers and OTS’s September 2006
Questions and Answers. The proposal
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499
also introduced nine proposed new
questions and answers (Q&As). 72 FR
37922. OTS also proposed four new and
revised Q&As that the OCC, Board, and
FDIC had adopted in the 2006 Questions
and Answers, primarily relating to
intermediate small savings associations.
Together, the agencies received
comments from 58 different parties. The
commenters represented financial
institutions and their trade associations,
community development advocates and
organizations, members of Congress,
and others.
As discussed below, this document
adopts the nine new Q&As that were
proposed in 2007, with revisions, as
appropriate, in response to comments
received. The agencies are also
adopting, with minor revisions, as
appropriate, all but one of the proposed
revised Q&As. The agencies are
withdrawing the proposed revisions to
Q&A § ll.23(e)–2.
The agencies also are proposing one
new and two revised Q&As, which are
discussed below. These proposed Q&As
have been developed in response to
comments received by the agencies.
The Interagency Questions and
Answers are grouped by the provision of
the CRA regulations that they discuss,
are presented in the same order as the
regulatory provisions, and employ an
abbreviated method of citing to the
regulations. For example, the small bank
performance standards for national
banks appear at 12 CFR 25.26; for
Federal Reserve System member banks
supervised by the Board, they appear at
12 CFR 228.26; for state nonmember
banks, they appear at 12 CFR 345.26;
and for thrifts, the small savings
association performance standards
appear at 12 CFR 563e.26. Accordingly,
the citation would be to 12 CFRll.26.
Each Q&A is numbered using a system
that consists of the regulatory citation
and a number, connected by a dash. For
example, the first Q&A addressing 12
CFRll.26 would be identified as
§ ll.26–1.
Although a particular Q&A may be
found under one regulatory provision,
e.g., 12 CFRll.22, which relates to the
lending test applicable to large
institutions, its content may also be
applicable to, for example, small
institutions, which are evaluated
pursuant to small institution
performance standards found at 12
CFRll.26. Thus, readers with a
particular interest in small institution
issues, for example, should also consult
the guidance that describes the lending,
investment, and service tests.
The Questions and Answers are
indexed to aid readers in locating
specific information in the document.
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The index contains keywords, listed
alphabetically, along with numerical
indicators of questions and answers that
relate to that keyword. The list of Q&As
addressing each keyword in the index is
not intended to be exhaustive. We
welcome suggestions for additional
entries to the index.
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Discussion of the Q&As Being Adopted
as Final
New Q&As Proposed in 2007
I. Investments in minority- or womenowned financial institutions and lowincome credit unions. The agencies
proposed a new Q&A § ll.12(g)–4 that
would interpret the statutory provision
that allows the agencies to consider as
a factor a majority-owned financial
institution’s activities in cooperation
with a minority- or women-owned
financial institution or low-income
credit union. See 12 U.S.C. 2903(b).
Twenty-five commenters addressed the
new Q&A as proposed. Although five
commenters believed that the proposed
guidance went directly against the
intent of the CRA regulations, the rest of
the commenters were generally in favor
of the new Q&A. Several commenters,
however, suggested additions or
modifications that could be made to the
guidance.
We are modifying the proposed Q&A
to address some of these comments.
Four commenters urged the agencies to
allow consideration of activities in
cooperation with minority- or womenowned financial institutions or lowincome credit unions only if the
majority-owned institution had
adequately addressed the credit needs of
its assessment area(s). The agencies
believe that the statute currently does
not impose such a limitation. However,
in response to the comment, we have
clarified that the impact of such
activities on a majority-owned
institution’s rating will be determined
in conjunction with an assessment of its
overall performance in its assessment
area(s).
Two commenters specifically asked
the agencies to provide examples of
‘‘other ventures’’ that could receive
consideration if engaged in by a
majority-owned financial institution in
cooperation with a minority- or womenowned financial institution or lowincome credit union. Several examples
of ‘‘other ventures’’ have been added to
the answer.
Six commenters suggested that
activities in cooperation with
community development financial
institutions (CDFIs) should be allowed
the same broader geographic allowance
that the statute allows for activities in
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cooperation with minority- or womenowned financial institutions or lowincome credit unions. The statute does
not provide a similar provision for
activities in cooperation with CDFIs.
Because the statute and regulation
otherwise generally focus on a financial
institution’s activities that benefit its
local community, the agencies do not
believe it is appropriate to apply the
relaxed geographic requirement to
CDFIs or other entities.
One other commenter suggested that
the agencies should delete the final
sentence of the proposed Q&A: ‘‘The
activities must, however, help meet the
credit needs of the local communities in
which the minority- or women-owned
institutions or low-income credit unions
are chartered.’’ The commenter’s
concern was that this sentence might be
read to require the majority-owned
financial institution to prove that its
involvement with the minority- or
women-owned institution or lowincome credit union ultimately can be
directly linked to a specific CRA-related
activity of the minority bank. The CRA
statute specifically conditions
consideration of activities in
cooperation with minority- or womenowned institutions or low-income credit
unions on those activities helping to
meet the credit needs of the local
communities in which the minority- or
women-owned institutions or lowincome credit unions are chartered.
Therefore, the sentence has not been
removed. The majority-owned financial
institution should have a general
understanding, prior to engaging in an
activity in cooperation with a minorityor women-owned institution or lowincome credit union, about how the
activity will help to meet the credit
needs of the community in which the
minority- or women-owned institution
or low-income credit union is chartered;
however, no specific type of proof is
required.
II. Intermediate small institutions’
affordable home mortgage loans and
small business and small farm loans.
The agencies received eleven comments
addressing proposed new Q&A
§ ll.12(h)–3, which would allow an
intermediate small institution to select
certain home mortgage, small business,
and small farm loans, which are not
required to be reported under the CRA
or Home Mortgage Disclosure Act
(HMDA) regulations, to be considered as
community development loans. All of
the commenters supported the proposed
Q&A.
The agencies are adopting the Q&A
with clarifying revisions based on
commenters’ questions and suggestions.
For example, one commenter asked
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whether an intermediate small
institution’s voluntary reporting of
small business or small farm loan data
would disqualify it from the optional
selection of some of those loans as
community development loans. The
guidance clarifies that optional
reporting of small business or small
farm loan data will not prevent an
intermediate small institution from
choosing some of those loans to be
considered as community development
loans unless the intermediate small
institution opts to be evaluated under
the lending, investment, and service
tests applicable to large institutions.
One commenter asked whether an
intermediate small institution that is
required to report home mortgage
lending under HMDA would be able to
opt to have some of its home mortgage
loans considered as community
development loans. Because the home
mortgage loans are required to be
reported under HMDA, they may be
considered only as home mortgage loans
(unless they are multifamily dwelling
loans).
The guidance has also been revised to
clarify that an intermediate small
institution may select individual loans
(other than home mortgage loans
reported under HMDA) to be considered
as community development loans. An
institution need not select an entire
portfolio for consideration as
community development loans.
The agencies note that intermediate
small institutions that opt to have
certain home mortgage, small business,
and small farm loans considered as
community development loans should
notify their examiners which loans it
has elected for this consideration prior
to or at the start of their CRA
examinations.
III. Examples of ‘‘other loan data.’’
The agencies received seventeen
comments addressing proposed new
Q&A § ll.22(a)(2)–4, which listed
examples of ‘‘other loan data’’ that
would be considered under the lending
test. Most of the commenters supported
the proposed Q&A. However, a number
of commenters suggested that some of
the types of ‘‘other loan data’’ should be
treated the same as direct lending.
Several commenters asserted that
letters of credit should be treated as loan
originations. They noted that, although
letters of credit are not immediately (if
ever) funded, the institution must
underwrite them in the same way direct
loans are underwritten and must also
ensure that funds are available for
eventual funding. Further, many
community development projects would
not be financed without the back-up
support provided by a financial
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institution’s letter of credit. For these
reasons, commenters urged that letters
of credit be considered as loan
originations.
The CRA regulations provide that
letters of credit will be considered as
‘‘other loan data.’’ The agencies cannot
change treatment of letters of credit in
the regulations through interpretation.
However, the agencies will consider the
issue again in the event they undertake
more comprehensive changes to the
CRA regulations. The agencies also plan
to remind examiners that letters of
credit may deserve specific mention in
the narrative of an institution’s public
performance evaluation.
Commenters also asserted that an
institution’s loans for mixed-income
housing should not be considered under
‘‘other loan data.’’ Instead, commenters
proposed that institutions should
receive consideration for such loans (or
investments) that enable community
development, such as mixed-income
projects that have an affordable housing
component, as community development
loans (or qualified investments).
The agencies are adopting Q&A
§ ll.22(a)(2)–4 as proposed. However,
as discussed below, we are also
proposing for comment a revised Q&A
§ ll.12(h)–8 discussing what is meant
by a ‘‘primary purpose of community
development.’’ If this proposed revision
is adopted as final, ‘‘loans that do not
have a primary purpose of community
development, but where a certain
amount or percentage of units is set
aside for affordable housing’’ would be
deleted from the list of examples of
‘‘other loan data’’ because these would
be covered in that revised guidance
which would allow an institution to
receive pro rata consideration for the
portion of a loan or investment that
helps to provide affordable housing to
low- or moderate-income individuals. In
the meantime, however, institutions
may continue to present such loans to
examiners as ‘‘other loan data.’’
IV. Purchased loan participations.
Ten commenters addressed proposed
Q&A § ll.22(a)(2)–6, which clarified
that the purchase of a loan participation
is treated as the purchase of a loan. The
majority of the commenters supported
the proposed guidance; however, one
commenter expressed concern that
loans could be resold numerous times
merely to inflate their value for CRA
evaluation purposes. We have modified
this Q&A to clarify that examiners will
consider whether loan participations
(and other loan purchases) have been
resold merely to inflate their value for
CRA purposes when they evaluate an
institution’s lending activity.
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V. Small business loans secured by a
one-to-four family residence. The
agencies proposed § ll.22(a)(2)–7 to
provide guidance about small business
and small farm loans where a dwelling
serves as collateral. As discussed in the
supplementary information published
with the proposed guidance, the new
Q&A was called for because of changes
to the Board’s Regulation C regarding
the treatment of refinancings of home
mortgage loans. See 72 FR at 37925. We
received twelve comments addressing
this proposed Q&A, primarily in
support of the proposed Q&A. We are
adopting the Q&A as proposed.
VI. Investments in a national or
regional fund. The agencies proposed
Q&A § ll.23(a)–2 to clarify how an
institution that makes a loan or
investment in a national or regional
community development fund may
demonstrate that the investment meets
the geographic requirements of the CRA
regulation. The proposed Q&A
suggested alternative methods for
documenting that the investment was
intended to benefit the institution’s
assessment area.
Thirty-three commenters addressed
this guidance. One theme in many of the
comments was that investments in
national funds should be treated in the
same manner as statewide or regional
funds. The regulations state that the
investment test evaluates an
institution’s record of helping to meet
the credit needs of its assessment area(s)
through qualified investments that
benefit its assessment area(s) or a
broader statewide or regional area that
includes the institution’s assessment
area(s). See 12 CFR 25.23(a), 228.23(a),
345.23(a), and 563e.23(a). Investments
in nationwide funds, like investments in
other funds, are subject to these
standards. An institution may wish to
provide documentation from a
nationwide fund to demonstrate the
geographic benefit to the institution’s
assessment area(s) or the broader
statewide or regional area that includes
its assessment area(s).
Because the proposed Q&A addressed
investments in both national and
regional funds, some commenters were
confused about the types of investments
the agencies intended to address in the
proposed Q&A. The proposed Q&A was
intended to address investments in
nationwide funds or in any fund that is
not limited to the statewide or regional
area that includes the institution’s
assessment area(s). Because other
existing Q&As address investments in
statewide and regional funds, Q&A
§ ll.23(a)–2 has been revised to
address specifically investments in
‘‘nationwide’’ funds. Institutions that
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501
invest in statewide or regional funds
should refer to Q&As § ll.12(h)–6 and
§ ll.12(h)–7 for guidance. The
guidance in these Q&As has not been
changed.
Commenters also addressed a number
of other issues. One commenter believed
that the requirements in the proposed
Q&A for an investment in a nationwide
fund were more rigorous than the
regulations required, in that the
proposed Q&A focused on benefit to an
institution’s assessment area, without
also considering benefit to the broader
statewide or regional area that includes
the institution’s assessment area(s). The
Q&A has been revised to clarify that
investments in nationwide funds will be
reviewed to determine whether they
directly or indirectly benefit one or
more of an institution’s assessment
areas or a broader statewide or regional
area that includes the institution’s
assessment area(s).
Several commenters understood the
proposal to suggest that the
documentation methods put forward in
the proposed Q&A was an exclusive,
mandatory list. The agencies have
clarified the final Q&A to provide that
the documentation methods identified
are among those that may, at the
institution’s option, be provided. The
agencies will accept any information
provided by an institution that
reasonably demonstrates that the
purpose, mandate, or function of a
nationwide fund includes serving
geographies or individuals located
within the institution’s assessment
area(s) or a broader statewide or regional
area that includes its assessment area(s).
Typically, information about where a
fund’s investments are expected to be
made or targeted often will be found in
the fund’s prospectus, or other
documents provided by the fund prior
to or at the time of the institution’s
investment, and the institution, at its
option, may provide such
documentation in connection with its
CRA evaluation.
Some commenters also asserted that
institutions should receive
consideration for the full dollar amount
of any investment in a nationwide fund
if at least one project in which the fund
invests is located in the institution’s
assessment area or the broader statewide
or regional area that includes the
institution’s assessment area. The
agencies have not incorporated this
specific recommendation into the text of
the Q&A. The agencies believe that the
final Q&A provides sufficient flexibility
to address a variety of different
circumstances, given the evolving
nature and significance of nationwide
funds.
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VII. Examination as an intermediate
small institution. Proposed new Q&A
§ ll.26(a)(2)–1 clarified that there is
no lag period between becoming an
intermediate small institution and being
examined as an intermediate small
institution. Eight commenters addressed
this new guidance; all were supportive.
The agencies are adopting this new Q&A
as proposed.
Several commenters suggested that
the agencies should provide technical
assistance to small institutions that are
about to become intermediate small
institutions at the institutions’ request.
The agencies currently provide
technical assistance to small institutions
in transition to becoming ‘‘intermediate
small’’ institutions.
VIII. Reporting of a participation in a
community development loan. The
agencies proposed Q&A § ll.42(b)(2)–
4 to clarify that institutions that
purchase community development loan
participations should report only the
amount of their purchase. The
supplementary information published
with the proposal noted that the
requirement to report only the dollar
amount of the participation purchased
for community development loans
differs from the requirements for
reporting small business and small farm
loan participations. When an institution
reports participations or purchases of
small business and small farm loans, it
must report the entire loan amount at
origination.
Eight commenters addressed this
proposed Q&A. One commenter
recommended the agencies adopt
consistent requirements governing the
way loans are reported. Another
commenter noted that different
requirements may be appropriate
because reporting the purchased amount
of the loan more accurately reflects the
actual dollar amount of an institution’s
community development lending. After
consideration of the comments received,
the agencies are adopting the Q&A as
proposed because the agencies believe
that reporting the amount purchased,
rather than the amount at origination,
more accurately portrays the
institution’s involvement in community
development lending.
IX. Refinanced or renewed community
development loans. The agencies
proposed Q&A § ll.42(b)(2)–5 to
clarify that institutions should collect
information about community
development loans that they refinance
or renew as loan originations. The Q&A
also notes that, generally, the same
limitations that apply to the reporting of
refinancings and renewals of small
business and small farm loans apply to
the reporting of refinancings and
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renewals of community development
loans. For example, an institution may
only report one origination (including a
renewal or refinancing treated as an
origination) per loan per year, unless an
increase in the loan amount is granted.
Eight commenters commented on, and
supported adoption of this proposed
Q&A. The agencies are adopting the
Q&A as proposed.
Revised Q&As Proposed in 2007 That
Were Specifically Described in the
Supplementary Information
I. Activities that promote economic
development. The agencies proposed to
revise Q&A § ll.12(g)(3)–1, which
describes the types of activities that
promote economic development by
financing small businesses and small
farms. The revisions clarified the
language of the guidance, and added
loans to or investments in Rural
Business Investment Companies (RBICs)
and New Markets Tax Credit-Eligible
Community Development Entities
(CDEs) as types of loans or investments
that the agencies will presume to
promote economic development.
Fourteen commenters addressed these
proposed revisions, including five that
represented community development
financial institutions (CDFIs). All
fourteen commenters supported
adoption of the proposed revisions. The
agencies are adopting the revised Q&A
as proposed.
CDFI representative commenters
urged the agencies to also presume that
loans to or investments in CDFIs
promote economic development. Q&A
§ ll.12(g)(3)–1 applies only to the
prong of the definition of ‘‘community
development’’ addressing promoting
economic development by financing
small businesses and small farms. The
agencies have not adopted this
suggestion. Existing Q&A § ll.12(t)–4
lists as examples of qualified
investments ‘‘investments, grants,
deposits, or shares in or to * * * CDFIs
that primarily lend or facilitate lending
in low- and moderate-income areas or to
low- and moderate-income individuals
in order to promote community
development, such as a CDFI that
promotes economic development on an
Indian reservation.’’ In addition, if a
CDFI were engaged in activities that
promote economic development by
financing small businesses or small
farms, investments in or loans to the
CDFI would have a primary purpose of
community development.
II. Examples of community
development loans. The agencies
proposed to revise Q&A § ll.12(h)–1,
which provides examples of community
development loans, to add a loan to a
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New Markets Tax Credit-Eligible CDE as
an example of a community
development loan. The agencies also
proposed to revise this Q&A by adding
a new bullet explaining that another
example of a community development
loan is a loan in an amount greater than
$1 million to a business, when the loan
is made as part of the Small Business
Administration’s 504 Certified
Development Company program. The
three commenters that addressed the
proposed revisions to this Q&A
recommended that they be adopted. The
agencies are adopting this Q&A as
proposed.
III. Examples of community
development services. The agencies
proposed to revise Q&A § ll.12(i)–3,
which lists examples of community
development services, to add as a new
example of a community service
‘‘increasing access to financial services
by opening or maintaining branches and
other facilities that help to revitalize or
stabilize a low- or moderate-income
geography, a designated disaster area, or
a distressed or underserved
nonmetropolitan middle-income
geography, unless the opening or
maintaining of such branches or other
facilities has been considered in the
evaluation of the institution’s retail
banking services under 12 CFR
ll.24(d).’’ The agencies also proposed
to revise this Q&A to highlight that
credit counseling that can assist
borrowers in avoiding foreclosure on
their homes would be a community
development service. Finally, the
agencies proposed to add individual
retirement accounts (IDAs) and free
payroll check cashing services that
increase access to financial services for
low- or moderate-income individuals to
the examples of financial services with
the primary purpose of community
development.
The agencies received ten comments
addressing these proposed revisions. All
of the commenters generally favored
adopting the proposed revisions. The
agencies are adopting the proposed Q&A
with several revisions.
One commenter suggested that the
reference to ‘‘free’’ check cashing should
be changed to ‘‘affordable’’ or ‘‘lowcost’’ check cashing services that
increase access to financial services for
low- or moderate-income individuals.
The agencies have revised the Q&A to
reference free and low-cost check
cashing. In addition, the agencies have
clarified that low-cost bank accounts
can be either savings or checking
accounts.
To help to address current economic
conditions and issues, the agencies have
added an additional example of a
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community development service:
Foreclosure prevention programs to
low-or moderate-income homeowners
who are facing foreclosure on their
primary residence with the objective of
providing affordable, sustainable, longterm loan modifications and
restructurings. The agencies have also
clarified that, to qualify as a community
development service, credit counseling
to assist borrowers in avoiding
foreclosure on their homes should be
targeted to low- and moderate-income
borrowers, based on the definition of
community development at 12 CFR ll
.12(g)(2).
Finally, in the proposed Q&A, an
existing bullet addressing school
savings programs and financial
education was split into two separate
bullets. This change has not been
adopted; however, the agencies are
adopting a minor revision incorporating
the commonly used term, ‘‘financial
literacy,’’ to the bullet.
IV. Federal Home Loan Bank (FHLB)
unpaid dividends. The agencies
proposed to revise Q&A § ll.12(t)–3 to
clarify that funds retained by FHLBs to
support the Affordable Housing Program
(AHP), rather than being paid out to
investor financial institutions as
dividends, are not qualified investments
by the financial institutions. The
agencies received three comments
addressing this proposed revision. One
commenter supported confirmation of
the existing policy. The other two
commenters were concerned that this
position may have the unintended effect
of creating a disincentive for FHLB
member institutions to participate in the
AHP and, ultimately, undermine
industry support for the program. The
agencies considered this comment, but
still believe that funds that are retained
by the FHLBs are not qualified
investments by the financial institutions
that do not receive them as dividends.
The Q&A continues to point out that
institutions’ other activities in
connection with the FHLBs’ AHP
program would be considered in an
institution’s CRA evaluation—for
example, providing technical assistance
to applicants would be considered as a
community development service. The
agencies are adopting this Q&A as
proposed.
V. Examples of qualified investments.
The agencies proposed to revise Q&A
§ ll.12(t)–4, which lists examples of
qualified investments, to add an
investment in a New Markets Tax
Credit-Eligible CDE as an additional
example. The proposal also would have
added as an example of a qualified
investment an investment in a
community development venture
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capital company that promotes
economic development by financing
small businesses. The agencies received
two comments on these proposed
revisions, which recommended
adoption. The Q&A is being adopted as
proposed.
VI. Small institution adjustment. The
agencies proposed to revise Q&A
§ ll.12(u)(2)–1, which provides
information about the annual
adjustments to the asset-size thresholds
for small institutions and intermediate
small institutions, to refer the reader to
the FFIEC’s Web site for historical and
current asset-size threshold information.
The two commenters that addressed this
proposed change supported its
adoption. The agencies are adopting the
Q&A as proposed.
VII. Responsive lending activities. The
agencies proposed to revise Q&A
§ ll.22(a)–1, which discusses types of
lending activities that may warrant
favorable consideration as being
responsive to the credit needs of the
institution’s assessment area(s). The
proposed revision highlighted that
establishing loan programs that provide
relief to low- and moderate-income
homeowners who are facing foreclosure
is a lending activity that would warrant
consideration as being responsive to the
needs of an institution’s assessment
areas. The agencies received six
comments addressing this proposed
revision. All supported the proposed
revision.
The agencies are adopting the
proposed revised Q&A with clarifying
changes. First, the agencies have
provided examples of the types of loan
programs that provide relief from
foreclosure, e.g., establising loan
programs with the objective of
providing affordable, sustainable, longterm relief through refinancings,
restructures, or modifications. Second,
the word, ‘‘homes,’’ has been replaced
by ‘‘primary residences’’ to clarify the
scope of the Q&A.
In April 2007, the agencies issued a
joint statement entitled, ‘‘Statement on
Working With Mortgage Borrowers.’’ In
that statement, the agencies encouraged
institutions to work with borrowers who
are financially unable to make their
contractual payment obligations on their
home loans. The statement noted that
financial institutions may receive
favorable CRA consideration for
programs that transition low- and
moderate-income borrowers from higher
cost loans to lower cost loans, provided
the loans are made in a safe and sound
manner. Consistent with the statement,
the proposed Q&A addressed only loan
programs that provide relief to low- and
moderate-income homeowners who are
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503
facing foreclosure as a type of lending
activity that would warrant
consideration as being responsive to the
credit needs of an institution’s
assessment areas. However, under the
regulation, the agencies assess an
institution’s responsiveness to credit
needs in each of its assessment area(s).
See 12 CFR parts 25, 228, 345 and 563e
at App. A(b)(1)(i). The agencies believe
that foreclosure assistance to
homeowners who are facing foreclosure
on their primary residences would be
responsive to the needs of an
institution’s assessment area(s).
Therefore, the agencies have revised the
final Q&A to refer to ‘‘homeowners’’
generally.
VIII. Constraints on affiliate lending.
Q&A § ll.22(c)(2)(i)–1 provides that
an affiliate may not claim a loan
origination or loan purchase for CRA
purposes if another institution claims
the same loan origination or loan
purchase. The agencies proposed to
revise this Q&A to add an example and
to clarify that the guidance applies to all
institutions, whether they are subject to
the lending test, small institution
examination standards, or the
community development test applicable
to wholesale or limited purpose
institutions. Six commenters addressed
these proposed revisions.
Two commenters supported the
clarifications. Four commenters
expressed concern that the new example
appears to give ‘‘double credit’’ for one
loan because the purchasing institution
is an affiliate of the originator. Each
financial institution that is subject to
CRA is separately evaluated for its CRA
performance, regardless of whether it
has affiliates that are also institutions
subject to the CRA. The CRA regulations
provide that the agencies will consider
both loan originations and loan
purchases when evaluating an
institution’s CRA performance. To
address commenters’ concerns about
sales of loans merely to inflate their
value for CRA purposes, however, the
agencies are adopting the revised Q&A
with a new cross reference to Q&As
§ ll.22(c)(2)(ii)–1 and
§ ll.22(c)(2)(ii)–2. These Q&As
provide that the manner in which loans
are allocated among affiliated
institutions for CRA purposes must
reflect actual business decisions about
the allocation of banking activities, and
should not be designed solely to
enhance their CRA evaluations.
IX. Retail banking services delivery
systems. The agencies proposed to
revise Q&A § ll.24(d)–1, which
explains how examiners evaluate the
availability of an institution’s systems
for delivering retail banking services.
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The proposed revision would conform
the existing Q&A to more closely track
the service test performance criteria in
the regulations. The agencies received
only one comment on the proposed
revisions to this Q&A, which supported
the clarifications to the Q&A. The
agencies are adopting the revised Q&A
as proposed.
X. Assessment areas may not extend
substantially beyond metropolitan
statistical area (MSA) boundaries. The
agencies proposed to revise Q&As
§ ll.41(e)(4)–1 and § ll.41(e)(4)–2,
which address the maximum size of an
assessment area, to adopt the revised
terminology in the Standards for
Defining Metropolitan and Micropolitan
Statistical Areas adopted by the Office
of Management and Budget, and to
incorporate guidance that the agencies
provided in connection with the
technical corrections made to the CRA
regulations in 2005. See 70 FR 15570.
The two comments on these proposed
revisions supported adopting them. The
agencies are adopting the revised Q&As
as proposed.
XI. Reporting data under the CRA
regulations. The agencies proposed to
revise Q&A § ll.42–1, which
addresses when an institution must
collect and report data, to refer generally
to the definition of a small institution,
rather than to the current dollar amount
of the asset threshold of such
institutions, because the asset threshold
is revised annually. The agencies also
revised the mailing address in the Q&A.
The agencies received no comments on
these proposed revisions. The revised
Q&A is being adopted as proposed.
XII. Reporting home equity lines of
credit for both home improvement and
business purposes. The agencies
proposed to revise Q&A § ll.42(a)–7,
which addresses the reporting of a home
equity line of credit, used in part for
home improvement purposes and used
in part for small business purposes, to
make the Q&A consistent with changes
that were made to the Board’s
Regulation C requirements. The
agencies received only one comment
addressing the proposed revised Q&A in
support of the proposed revision. The
agencies are adopting the revised Q&A
as proposed.
XIII. Participations in small business
or small farm loans. The agencies
proposed to revise Q&A § ll.42(a)(2)–
1, which provides guidance regarding
the reporting of the amount of a small
business or small farm loan that an
institution purchases, to clarify that the
guidance also applies to purchases of
small business or small farm loan
participations. The agencies received
five comments addressing this proposed
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revision. One commenter agreed that the
reporting of loan participations
purchased should be treated in the same
manner as the reporting of whole loans
purchased. The other four commenters
addressed the inconsistency between
the reporting requirements for small
business and small farm loan purchases
(either whole loans or participations in
loans) and the reporting requirements
for community development loan
purchases (whole or partial). As
discussed above, the CRA regulations at
12 CFR ll.42(a)(2) require the
reporting of the loan amount at
origination when reporting small
business and small farm loan data.
Thus, the agencies are adopting the
revised Q&A as proposed.
Withdrawal of Proposed Revisions to
Existing Q&A § ll.23(e)–2
Q&A § ll.23(e)–2 addresses how
examiners evaluate an institution’s
qualified investment in a fund with a
primary purpose of community
development. The agencies proposed to
revise the Q&A’s discussion of
consideration of legally binding
commitments recorded by the
institution according to GAAP. The
agencies received two comments, both
of which opposed the change. In
response to these comments, and
because the proposal was inconsistent
with an interagency CRA interpretive
letter published by the agencies in 1997
(OCC I.L. No. 800 (Sept. 11, 1997)), the
agencies are withdrawing the proposal.
Therefore, when evaluating a financial
institution, examiners will continue to
include in the dollar amount of
qualified investments any legally
binding commitments recorded by the
institution according to GAAP.
Clarifying Revisions to Existing Q&As
Q&A § ll.12(g)–3
Three commenters addressed Q&A
§ ll.12(g)–3, which addresses
flexibility in considering performance in
high-cost areas. Q&A § ll.12(g)–3
provides an example of a situation when
examiners could take into account the
high cost of housing when an institution
provides a community development
loan or qualified investment to an
organization that assists middle-income,
as well as low- and moderate-income,
people and areas. Even though the
agencies had not proposed revisions to
this existing guidance, after
consideration of the comments, the
agencies are revising this Q&A by
adding a cross reference to Q&A
§ ll.12(h)–8, which provides
information on ‘‘primary purpose’’ of
community development.
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Q&A § ll.12(g)(4)(i)–1
The agencies did not receive any
comments directly mentioning Q&A
§ ll.12(g)(4)(i)–1. However, several
commenters expressed their general
support for the additional foreclosure
prevention references that were
proposed in other Q&As. Q&A
§ ll.12(g)(4)(i)–1 addresses activities
that are considered to ‘‘revitalize or
stabilize’’ a low- or moderate-income
geography. Based on these comments,
the following example has been added
to the answer: ‘‘For example, providing
foreclosure prevention programs with
the objective of providing affordable,
sustainable, long-term loan
restructurings or modifications to
homeowners in low- and moderateincome geographies, consistent with
safe and sound banking practices, may
help to revitalize or stabilize those
geographies.’’
OTS Request for Comments on
Conforming Revisions
OTS specifically requested comment
on several Q&As that it proposed to
conform OTS guidance to guidance
previously adopted by the OCC, Board,
and FDIC. Five commenters addressed
OTS’s conforming revisions. They
unanimously supported the efforts of
OTS to be consistent with the other
agencies. OTS is adopting the Q&As as
proposed.
Revised and New Q&As Being Proposed
for Comment
Proposed New Q&A: Community
Services Targeted to Low- or Moderateincome Individuals
In response to suggestions made by
commenters, the agencies are proposing
a new Q&A that would provide
examples of ways an institution, which
provides community services, could
determine that the community services
are targeted to low- and moderateincome individuals when the institution
does not know the actual income of the
individuals. The text of the proposed
Q&A follows:
fl§ ll.12(g)(2)– 1: Community
development includes community
services targeted to low- or moderateincome individuals. What are examples
of ways that an institution could
determine that community services are
offered to low- or moderate-income
individuals?
A1: Examples of ways in which an
institution could determine that
community services are targeted to lowor moderate-income persons include:
• The community service is targeted
to the clients of a nonprofit organization
that has a defined mission of serving
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low- and moderate-income persons, or,
because of government grants, for
example, is limited to offering services
only to low- or moderate-income
persons.
• The community service is offered
by a nonprofit organization that is
located in and serves a low- or
moderate-income geography.
• The community service is
conducted in a low- or moderate-income
area and targeted to the residents of the
area.
• The community service is offered at
a workplace to workers who are lowand moderate-income, based on readily
available data for the average wage for
workers in that particular occupation or
industry (see, e.g., https://www.bls.gov/
bls/blswage.htm (Bureau of Labor
Statistics)).fi
Proposed Revised Q&As: Primary
Purpose of Community Development
As discussed above, a number of
commenters suggested that loans or
investments that provide some
affordable housing to low- or moderateincome individuals should be
considered as ‘‘community
development.’’ The regulations require
community development activities to
have a ‘‘primary purpose of community
development.’’ See 12 CFRll.12(h),
ll.12(i), and .12(t).
Q&A § ll.12(h)–8 generally
provides two methods of determining
whether an activity has a primary
purpose of community development: (1)
If a majority of the dollars or
beneficiaries of the activity are
identifiable to one or more of the
enumerated community development
purposes, then an activity will be
considered to possess the requisite
primary purpose; and (2) If the express,
bona fide intent of the activity, as stated,
for example, in a prospectus, loan
proposal, or community action plan, is
primarily one or more of the
enumerated community development
purposes; the activity is specifically
structured (given any relevant market or
legal constraints or performance context
factors) to achieve the expressed
community development purpose; and
the activity accomplishes, or is
reasonably certain to accomplish, the
community development purpose
involved, then the requisite primary
purpose may be found.
The agencies have generally indicated
that if an activity has a primary purpose
of community development (determined
by either method above), the entire
investment, loan, or service would be
considered in an institution’s CRA
evaluation. However, if an activity does
not have a primary purpose of
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community development applying these
standards, then it would not be
considered as a qualified investment,
community development loan, or
community development service.
The agencies are proposing to revise
Q&A § ll.12(h)–8 to allow
consideration for an activity that
provides some affordable housing
targeted to low- or moderate-income
individuals, but where it would not be
deemed to have a primary purpose of
community development measured by a
majority of the entire activity’s benefits
or dollar value, or by relying on the
express purpose of the activity. The
Q&A would specifically allow activities
related to the provision of mixedincome housing, such as in connection
with a development that has a mixedincome housing component or an
affordable housing set-aside required by
federal, state, or local government, to be
eligible for consideration as an activity
that has a ‘‘primary purpose’’ of
community development at the election
of the institution. In those cases, an
institution would receive pro rata
consideration for the portion of the
activity that helps to provide affordable
housing to low- or moderate-income
individuals.
The text of the proposed revised Q&A
follows:
§ ll.12(h)—8: What is meant by the
term ‘‘primary purpose’’ as that term is
used to define what constitutes a
community development loan, a
qualified investment, or a community
development service?
A8. A loan, investment, or service has
as its primary purpose community
development when it is designed for the
express purpose of revitalizing or
stabilizing low- or moderate-income
areas, designated disaster areas, or
underserved or distressed
nonmetropolitan middle-income areas,
providing affordable housing for, or
community services targeted to, low- or
moderate-income persons, or promoting
economic development by financing
small businesses and farms that meet
the requirements set forth in 12 CFR
ll.12(g). To determine whether an
activity is designed for an express
community development purpose, the
agencies apply one of two approaches.
First, if a majority of the dollars or
beneficiaries of the activity are
identifiable to one or more of the
enumerated community development
purposes, then the activity will be
considered to possess the requisite
primary purpose. Alternatively, where
the measurable portion of any benefit
bestowed or dollars applied to the
community development purpose is less
than a majority of the entire activity’s
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505
benefits or dollar value, then the activity
may still be considered to possess the
requisite primary purposefl, and the
institution may receive CRA
consideration for the entire activity,fi if
(1) The express, bona fide intent of the
activity, as stated, for example, in a
prospectus, loan proposal, or
community action plan, is primarily one
or more of the enumerated community
development purposes; (2) the activity
is specifically structured (given any
relevant market or legal constraints or
performance context factors) to achieve
the expressed community development
purpose; and (3) the activity
accomplishes, or is reasonably certain to
accomplish, the community
development purpose involved.
flGenerally, a loan, investment, or
service will be determined to have a
‘‘primary purpose’’ of community
development only if it meets the criteria
described above. However, an activity
also may be deemed to have a ‘‘primary
purpose’’ of community development in
certain other limited circumstances in
which these criteria have not been met.
Specifically, activities related to the
provision of mixed-income housing,
such as in connection with a
development that has a mixed-income
housing component or an affordable
housing set-aside required by federal,
state, or local government, also would
be eligible for consideration as an
activity that has a ‘‘primary purpose’’ of
community development at the election
of the institution. In such cases, an
institution may receive pro rata
consideration for the portion of such
activities that helps to provide
affordable housing to low- or moderateincome individuals. For example, if an
institution makes a $10 million loan to
finance a mixed-income housing
development in which ten percent of
the units will be set aside as affordable
housing for low- and moderate-income
individuals and ten percent of the funds
will be used for the cost of constructing
those units, the institution may elect to
treat $1 million of such loan as a
community development loan.fi
The fact that an activity provides
indirect or short-term benefits to low- or
moderate-income persons does not
make the activity community
development, nor does the mere
presence of such indirect or short-term
benefits constitute a primary purpose of
community development. Financial
institutions that want examiners to
consider certain activities (under either
approach) should be prepared to
demonstrate the activities’
qualifications.
Because this proposed revision would
be a significant change to the agencies’
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general ‘‘all or nothing’’ CRA
consideration policy for community
development loans, qualified
investments, and community
development services, the agencies
solicit public comment on the proposed
revision. We specifically request
comment on the following:
• Will the proposed revision,
allowing pro rata CRA consideration for
low- and moderate-income housing setasides, spur the construction and
rehabilitation of housing for low- and
moderate-income persons? Why or why
not?
• Should the special pro rata
consideration be restricted only to
instances where a governmental entity
requires a set aside of a certain number
or percentage of units as housing
affordable for low- or moderate-income
housing (as opposed to voluntary
designation of low- and moderateincome units by a developer)?
• How should the amount of the pro
rata share be determined for reporting
purposes—should institutions be
required to report the actual funds
attributable to the targeted units or
should they report a proportional share,
based on the percentage of set-aside
units? For example, if an institution
makes a $1 million loan for a
development in which ten percent of
the units are set aside as affordable
housing for low- or moderate-income
individuals, but only six percent of the
loan proceeds are used to construct the
units, should the intitution report ten
percent of the total amount of the loan
($1 million) or six percent ($600,000)?
• Should the pro rata treatment apply
only to affordable housing or should
institutions also be able to receive pro
rata treatment for loans or investments
with other community development
purposes?
• Would this change in policy lead to
unjustifiable inflation of community
development activities?
If the proposed revision to Q&A
§ ll.12(h)–8, above, is adopted, the
agencies would also revise Q&A
§ ll.42(b)(2)–3 to address data
collection and reporting of the pro rata
share of the mixed-income housing
loans described in the Q&A. If an
institution were to elect to have the
portion of mixed-income housing loans
set aside for low- or moderate-income
housing considered as community
development loans, in order to receive
consideration for such loans, the
institution would need to collect and
report data on only the portions of the
loans that provide housing for low- or
moderate-income individuals. The
proposed revision to Q&A
§ ll.42(b)(2)–3 follows:
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§ ll.42(b)(2)–3: When the primary
purpose of a loan is to finance an
affordable housing project for low- or
moderate-income individuals, but, for
example, only 40 percent of the units in
question will actually be occupied by
individuals or families with low or
moderate incomes, should the entire
loan amount be reported as a
community development loan?
A3.flIt depends.fi As long as the
primary purpose of the loan is a
community development purpose flas
described in Q&A § ll.12 (h)–8fi, the
full amount of the institution’s loan
should be included in its reporting of
aggregate amounts of community
development lending. [However]flEven
though the entire amount of the loan is
reportedfi, as noted in Q&A
§ ll.22(b)(4)–1, examiners may make
qualitative distinctions among
community development loans on the
basis of the extent to which the loan
advances the community development
purpose.
flIn addition, if an institution that
reports CRA data elects to request
consideration for loans that provide
mixed-income housing where only a
portion of the loan has community
development as its primary purpose,
such as in connection with a
development that has a mixed-income
housing component or an affordable
housing set-aside required by federal,
state, or local government, the
institution must report only the pro rata
dollar amount of the portion of the loan
that provides affordable housing to lowor moderate-income individuals. See
Q&A § ll.12(h)–8 for a discussion of
‘‘primary purpose’’ of community
development describing the distinction
between the types of loans that would
be reported in full and those for which
only the pro rata amount would be
reported.fi
Finally, as previously discussed, if the
proposed revision to Q&A § ll.12(h)–
8 is adopted as final, Q&A
§ ll.22(a)(2)–4, which provides
examples of ‘‘other loan data,’’ would be
revised to delete ‘‘loans that do not have
a primary purpose of community
development, but where a certain
amount or percentage of units is set
aside for affordable housing.’’
Solicitation of Comments Regarding the
Use of ‘‘Plain Language’’
Section 722 of the Gramm-LeachBliley Act of 1999, 12 U.S.C. 4809,
requires the agencies to use ‘‘plain
language’’ in all proposed and final
rules published after January 1, 2000.
Although this guidance is not a
proposed or final rule, comments are
nevertheless invited on whether the
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interagency questions and answers are
stated clearly and effectively organized,
and how the guidance might be revised
to make it easier to read.
The text of the final Interagency
Questions and Answers follows:
Interagency Questions and Answers
Regarding Community Reinvestment
§ ll.11—Authority, purposes, and
scope
§ ll.11(c) Scope
§§ ll.11(c)(3) & 563e.11(c)(2) Certain
special purpose institutions
§§ ll.11(c)(3) & 563e.11(c)(2)–1: Is
the list of special purpose institutions
exclusive?
A1. No, there may be other examples
of special purpose institutions. These
institutions engage in specialized
activities that do not involve granting
credit to the public in the ordinary
course of business. Special purpose
institutions typically serve as
correspondent banks, trust companies,
or clearing agents or engage only in
specialized services, such as cash
management controlled disbursement
services. A financial institution,
however, does not become a special
purpose institution merely by ceasing to
make loans and, instead, making
investments and providing other retail
banking services.
§§ ll.11(c)(3) & 563e.11(c)(2)–2: To
be a special purpose institution, must
an institution limit its activities in its
charter?
A2. No. A special purpose institution
may, but is not required to, limit the
scope of its activities in its charter,
articles of association, or other corporate
organizational documents. An
institution that does not have legal
limitations on its activities, but has
voluntarily limited its activities,
however, would no longer be exempt
from Community Reinvestment Act
(CRA) requirements if it subsequently
engaged in activities that involve
granting credit to the public in the
ordinary course of business. An
institution that believes it is exempt
from CRA as a special purpose
institution should seek confirmation of
this status from its supervisory agency.
§ ll.12—Definitions
§ ll.12(a) Affiliate
§ ll.12(a)–1: Does the definition of
‘‘affiliate’’ include subsidiaries of an
institution?
A1. Yes, ‘‘affiliate’’ includes any
company that controls, is controlled by,
or is under common control with
another company. An institution’s
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subsidiary is controlled by the
institution and is, therefore, an affiliate.
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§ ll.12(f) Branch
§ ll.12(f)–1: Do the definitions of
‘‘branch,’’ ‘‘automated teller machine
(ATM),’’ and ‘‘remote service facility
(RSF)’’ include mobile branches, ATMs,
and RSFs?
A1. Yes. Staffed mobile offices that
are authorized as branches are
considered ‘‘branches,’’ and mobile
ATMs and RSFs are considered ‘‘ATMs’’
and ‘‘RSFs.’’
§ ll.12(f)–2: Are loan production
offices (LPOs) branches for purposes of
the CRA?
A2. LPOs and other offices are not
‘‘branches’’ unless they are authorized
as branches of the institution through
the regulatory approval process of the
institution’s supervisory agency.
§ ll.12(g) Community development
§ ll.12(g)–1: Are community
development activities limited to those
that promote economic development?
A1. No. Although the definition of
‘‘community development’’ includes
activities that promote economic
development by financing small
businesses or farms, the rule does not
limit community development loans
and services and qualified investments
to those activities. Community
development also includes communityor tribal-based child care, educational,
health, or social services targeted to
low- or moderate-income persons,
affordable housing for low- or moderateincome individuals, and activities that
revitalize or stabilize low- or moderateincome areas, designated disaster areas,
or underserved or distressed
nonmetropolitan middle-income
geographies.
§ ll.12(g)–2: Must a community
development activity occur inside a lowor moderate-income area, designated
disaster area, or underserved or
distressed nonmetropolitan middleincome area in order for an institution
to receive CRA consideration for the
activity?
A2. No. Community development
includes activities, regardless of their
location, that provide affordable
housing for, or community services
targeted to, low- or moderate-income
individuals and activities that promote
economic development by financing
small businesses and farms. Activities
that stabilize or revitalize particular
low- or moderate-income areas,
designated disaster areas, or
underserved or distressed
nonmetropolitan middle-income areas
(including by creating, retaining, or
improving jobs for low- or moderate-
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income persons) also qualify as
community development, even if the
activities are not located in these areas.
One example is financing a supermarket
that serves as an anchor store in a small
strip mall located at the edge of a
middle-income area, if the mall
stabilizes the adjacent low-income
community by providing needed
shopping services that are not otherwise
available in the low-income community.
§ ll.12(g)–3: Does the regulation
provide flexibility in considering
performance in high-cost areas?
A3. Yes, the flexibility of the
performance standards allows
examiners to account in their
evaluations for conditions in high-cost
areas. Examiners consider lending and
services to individuals and geographies
of all income levels and businesses of
all sizes and revenues. In addition, the
flexibility in the requirement that
community development loans,
community development services, and
qualified investments have as their
‘‘primary’’ purpose community
development allows examiners to
account for conditions in high-cost
areas. For example, examiners could
take into account the fact that activities
address a credit shortage among middleincome people or areas caused by the
disproportionately high cost of building,
maintaining or acquiring a house when
determining whether an institution’s
loan to or investment in an organization
that funds affordable housing for
middle-income people or areas, as well
as low- and moderate-income people or
areas, has as its primary purpose
community development. See also Q&A
§ ll.12(h)–8 for more information on
‘‘primary purpose.’’
§ ll.12(g)–4: The CRA provides
that, in assessing the CRA performance
of non-minority- and non-women-owned
(majority-owned) financial institutions,
examiners may consider as a factor
capital investments, loan participations,
and other ventures undertaken by the
institutions in cooperation with
minority- or women-owned financial
institutions and low-income credit
unions (MWLIs), provided that these
activities help meet the credit needs of
local communities in which the MWLIs
are chartered. Must such activities also
benefit the majority-owned financial
institution’s assessment area?
A4. No. Although the regulations
generally provide that an institution’s
CRA activities will be evaluated for the
extent to which they benefit the
institution’s assessment area(s) or a
broader statewide or regional area that
includes the institution’s assessment
area(s), the agencies apply a broader
geographic criterion when evaluating
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capital investments, loan participations,
and other ventures undertaken by that
institution in cooperation with MWLIs,
as provided by the CRA. Thus, such
activities will be favorably considered
in the CRA performance evaluation of
the institution (as loans, investments, or
services, as appropriate), even if the
MWLIs are not located in, or such
activities do not benefit, the assessment
area(s) of the majority-owned institution
or the broader statewide or regional area
that includes its assessment area(s). The
activities must, however, help meet the
credit needs of the local communities in
which the MWLIs are chartered. The
impact of a majority-owned institution’s
activities in cooperation with MWLIs on
the majority-owned institution’s CRA
rating will be determined in conjunction
with its overall performance in its
assessment area(s).
Examples of activities undertaken by
a majority-owned financial institution
in cooperation with MWLIs that would
receive CRA consideration may include:
• Making a deposit or capital
investment;
• Purchasing a participation in a loan;
• Loaning an officer or providing
other technical expertise to assist an
MWLI in improving its lending policies
and practices;
• Providing financial support to
enable an MWLI to partner with schools
or universities to offer financial literacy
education to members of its local
community; or
• Providing free or discounted data
processing systems, or office facilities to
aid an MWLI in serving its customers.
§ ll.12(g)(1) Affordable Housing
(Including Multifamily Rental Housing)
for Low- or Moderate-income
Individuals
§ ll.12(g)(1)–1: When determining
whether a project is ‘‘affordable housing
for low- or moderate-income
individuals,’’ thereby meeting the
definition of ‘‘community
development,’’ will it be sufficient to use
a formula that relates the cost of
ownership, rental, or borrowing to the
income levels in the area as the only
factor, regardless of whether the users,
likely users, or beneficiaries of that
affordable housing are low- or
moderate-income individuals?
A1. The concept of ‘‘affordable
housing’’ for low- or moderate-income
individuals does hinge on whether lowor moderate-income individuals benefit,
or are likely to benefit, from the
housing. It would be inappropriate to
give consideration to a project that
exclusively or predominately houses
families that are not low- or moderateincome simply because the rents or
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housing prices are set according to a
particular formula.
For projects that do not yet have
occupants, and for which the income of
the potential occupants cannot be
determined in advance, or in other
projects where the income of occupants
cannot be verified, examiners will
review factors such as demographic,
economic, and market data to determine
the likelihood that the housing will
‘‘primarily’’ accommodate low- or
moderate-income individuals. For
example, examiners may look at median
rents of the assessment area and the
project; the median home value of either
the assessment area, low- or moderateincome geographies or the project; the
low- or moderate-income population in
the area of the project; or the past
performance record of the
organization(s) undertaking the project.
Further, such a project could receive
consideration if its express, bona fide
intent, as stated, for example, in a
prospectus, loan proposal, or
community action plan, is community
development.
§ ll.12(g)(3) Activities That
Promote Economic Development by
Financing Businesses or Farms That
Meet Certain Size Eligibility Standards
§ ll.12(g)(3)–1: ‘‘Community
development’’ includes activities that
promote economic development by
financing businesses or farms that meet
certain size eligibility standards. Are all
activities that finance businesses and
farms that meet these size eligibility
standards considered to be community
development?
A1. No. The concept of ‘‘community
development’’ under 12
CFRll.12(g)(3) involves both a ‘‘size’’
test and a ‘‘purpose’’ test. An
institution’s loan, investment, or service
meets the ‘‘size’’ test if it finances, either
directly or through an intermediary,
entities that either meet the size
eligibility standards of the Small
Business Administration’s Development
Company (SBDC) or Small Business
Investment Company (SBIC) programs,
or have gross annual revenues of $1
million or less.
To meet the ‘‘purpose test,’’ the
institution’s loan, investment, or service
must promote economic development.
These activities are considered to
promote economic development if they
support permanent job creation,
retention, and/or improvement for
persons who are currently low- or
moderate-income, or support permanent
job creation, retention, and/or
improvement either in low- or
moderate-income geographies or in
areas targeted for redevelopment by
Federal, state, local, or tribal
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governments. The agencies will
presume that any loan to or investment
in an SBDC, SBIC, Rural Business
Investment Company, New Markets
Venture Capital Company, or New
Markets Tax Credit-eligible Community
Development Entity promotes economic
development. (But also refer to Q&As
§ ll.42(b)(2)–2, § ll.12(h)–2, and
§ ll.12(h)–3 for more information
about which loans may be considered
community development loans.)
In addition to their quantitative
assessment of the amount of a financial
institution’s community development
activities, examiners must make
qualitative assessments of an
institution’s leadership in community
development matters and the
complexity, responsiveness, and impact
of the community development
activities of the institution. In reaching
a conclusion about the impact of an
institution’s community development
activities, examiners may, for example,
determine that a loan to a small
business in a low- or moderate-income
geography that provides needed jobs
and services in that area may have a
greater impact and be more responsive
to the community credit needs than
does a loan to a small business in the
same geography that does not directly
provide additional jobs or services to
the community.
§ ll.12(g)(4) Activities That Revitalize
or Stabilize Certain Geographies
§ ll.12(g)(4)–1: Is the revised
definition of community development,
effective September 1, 2005 (under the
OCC, Board, and FDIC rules) and
effective April 12, 2006 (under OTS’s
rule), applicable to all institutions or
only to intermediate small institutions?
A1. The revised definition of
community development is applicable
to all institutions. Examiners will not
use the revised definition to qualify
activities that were funded or provided
prior to September 1, 2005 (under the
OCC, Board, and FDIC rules) or prior to
April 12, 2006 (under OTS’s rule).
§ ll.12(g)(4)–2: Will activities that
provide housing for middle-income and
upper-income persons qualify for
favorable consideration as community
development activities when they help
to revitalize or stabilize a distressed or
underserved nonmetropolitan middleincome geography or designated
disaster areas?
A2. An activity that provides housing
for middle- or upper-income individuals
qualifies as an activity that revitalizes or
stabilizes a distressed nonmetropolitan
middle-income geography or a
designated disaster area if the housing
directly helps to revitalize or stabilize
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the community by attracting new, or
retaining existing, businesses or
residents and, in the case of a
designated disaster area, is related to
disaster recovery. The Agencies
generally will consider all activities that
revitalize or stabilize a distressed
nonmetropolitan middle-income
geography or designated disaster area,
but will give greater weight to those
activities that are most responsive to
community needs, including needs of
low- or moderate-income individuals or
neighborhoods. Thus, for example, a
loan solely to develop middle- or upperincome housing in a community in need
of low- and moderate-income housing
would be given very little weight if
there is only a short-term benefit to lowand moderate-income individuals in the
community through the creation of
temporary construction jobs. (Except in
connection with intermediate small
institutions, a housing-related loan is
not evaluated as a ‘‘community
development loan’’ if it has been
reported or collected by the institution
or its affiliate as a home mortgage loan,
unless it is a multifamily dwelling loan.
See 12 CFRll.12(h)(2)(i) and Q&As
§ ll.12(h)–2 and § ll.12(h)–3.) An
activity will be presumed to revitalize or
stabilize such a geography or area if the
activity is consistent with a bona fide
government revitalization or
stabilization plan or disaster recovery
plan. See Q&As § ll.12(g)(4)(i)–1 and
§ ll.12(h)–5.
In underserved nonmetropolitan
middle-income geographies, activities
that provide housing for middle- and
upper-income individuals may qualify
as activities that revitalize or stabilize
such underserved areas if the activities
also provide housing for low- or
moderate-income individuals. For
example, a loan to build a mixedincome housing development that
provides housing for middle- and
upper-income individuals in an
underserved nonmetropolitan middleincome geography would receive
positive consideration if it also provides
housing for low- or moderate-income
individuals.
§ ll.12(g)(4)(i) Activities That
Revitalize or Stabilize Low- or
Moderate-income Geographies
§ ll.12(g)(4)(i)–1: What activities
are considered to ‘‘revitalize or
stabilize’’ a low- or moderate-income
geography, and how are those activities
considered?
A1. Activities that revitalize or
stabilize a low- or moderate-income
geography are activities that help to
attract new, or retain existing,
businesses or residents. Examiners will
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presume that an activity revitalizes or
stabilizes a low- or moderate-income
geography if the activity has been
approved by the governing board of an
Enterprise Community or Empowerment
Zone (designated pursuant to 26 U.S.C.
1391) and is consistent with the board’s
strategic plan. They will make the same
presumption if the activity has received
similar official designation as consistent
with a federal, state, local, or tribal
government plan for the revitalization or
stabilization of the low- or moderateincome geography. For example,
foreclosure prevention programs with
the objective of providing affordable,
sustainable, long-term loan
restructurings or modifications to
homeowners in low- or moderateincome geographies, consistent with
safe and sound banking practices, may
help to revitalize or stabilize those
geographies.
To determine whether other activities
revitalize or stabilize a low- or
moderate-income geography, examiners
will evaluate the activity’s actual impact
on the geography, if information about
this is available. If not, examiners will
determine whether the activity is
consistent with the community’s formal
or informal plans for the revitalization
and stabilization of the low- or
moderate-income geography. For more
information on what activities revitalize
or stabilize a low- or moderate-income
geography, see Q&As § ll.12(g)–2 and
§ ll.12(h)–5.
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§ ll.12(g)(4)(ii) Activities That
Revitalize or Stabilize Designated
Disaster Areas
§ ll.12(g)(4)(ii)–1: What is a
‘‘designated disaster area’’ and how
long does it last?
A1. A ‘‘designated disaster area’’ is a
major disaster area designated by the
federal government. Such disaster
designations include, in particular,
Major Disaster Declarations
administered by the Federal Emergency
Management Agency (FEMA) (https://
www.fema.gov), but excludes counties
designated to receive only FEMA Public
Assistance Emergency Work Category A
(Debris Removal) and/or Category B
(Emergency Protective Measures).
Examiners will consider institution
activities related to disaster recovery
that revitalize or stabilize a designated
disaster area for 36 months following
the date of designation. Where there is
a demonstrable community need to
extend the period for recognizing
revitalization or stabilization activities
in a particular disaster area to assist in
long-term recovery efforts, this time
period may be extended.
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§ ll.12(g)(4)(ii)–2: What activities
are considered to ‘‘revitalize or
stabilize’’ a designated disaster area,
and how are those activities considered?
A2. The Agencies generally will
consider an activity to revitalize or
stabilize a designated disaster area if it
helps to attract new, or retain existing,
businesses or residents and is related to
disaster recovery. An activity will be
presumed to revitalize or stabilize the
area if the activity is consistent with a
bona fide government revitalization or
stabilization plan or disaster recovery
plan. The Agencies generally will
consider all activities relating to disaster
recovery that revitalize or stabilize a
designated disaster area, but will give
greater weight to those activities that are
most responsive to community needs,
including the needs of low- or
moderate-income individuals or
neighborhoods. Qualifying activities
may include, for example, providing
financing to help retain businesses in
the area that employ local residents,
including low- and moderate-income
individuals; providing financing to
attract a major new employer that will
create long-term job opportunities,
including for low- and moderate-income
individuals; providing financing or
other assistance for essential
community-wide infrastructure,
community services, and rebuilding
needs; and activities that provide
housing, financial assistance, and
services to individuals in designated
disaster areas and to individuals who
have been displaced from those areas,
including low- and moderate-income
individuals (see, e.g., Q&As § ll.12(i)–
3; § ll.12(t)–4; § ll.22(b)(2) & (3)–4;
§ ll.22(b)(2) & (3)–5; and
§ ll.24(d)(3)–1).
§ ll.12(g)(4)(iii) Activities That
Revitalize or Stabilize Distressed or
Underserved Nonmetropolitan Middleincome Geographies
§ ll.12(g)(4)(iii)–1: What criteria are
used to identify distressed or
underserved nonmetropolitan, middleincome geographies?
A1. Eligible nonmetropolitan middleincome geographies are those
designated by the Agencies as being in
distress or that could have difficulty
meeting essential community needs
(underserved). A particular geography
could be designated as both distressed
and underserved. As defined in 12 CFR
ll.12(k), a geography is a census tract
delineated by the United States Bureau
of the Census.
A nonmetropolitan middle-income
geography will be designated as
distressed if it is in a county that meets
one or more of the following triggers: (1)
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509
An unemployment rate of at least 1.5
times the national average, (2) a poverty
rate of 20 percent or more, or (3) a
population loss of 10 percent or more
between the previous and most recent
decennial census or a net migration loss
of five percent or more over the fiveyear period preceding the most recent
census.
A nonmetropolitan middle-income
geography will be designated as
underserved if it meets criteria for
population size, density, and dispersion
that indicate the area’s population is
sufficiently small, thin, and distant from
a population center that the tract is
likely to have difficulty financing the
fixed costs of meeting essential
community needs. The Agencies will
use as the basis for these designations
the ‘‘urban influence codes,’’ numbered
‘‘7,’’ ‘‘10,’’ ‘‘11,’’ and ‘‘12,’’ maintained
by the Economic Research Service of the
United States Department of
Agriculture.
The Agencies publish data source
information along with the list of
eligible nonmetropolitan census tracts
on the Federal Financial Institutions
Examination Council Web site (https://
www.ffiec.gov).
§ ll.12(g)(4)(iii)–2: How often will
the Agencies update the list of
designated distressed and underserved
nonmetropolitan middle-income
geographies?
A2. The Agencies will review and
update the list annually. The list is
published on the Federal Financial
Institutions Examination Council Web
site (https://www.ffiec.gov).
To the extent that changes to the
designated census tracts occur, the
Agencies have determined to adopt a
one-year ‘‘lag period.’’ This lag period
will be in effect for the twelve months
immediately following the date when a
census tract that was designated as
distressed or underserved is removed
from the designated list. Revitalization
or stabilization activities undertaken
during the lag period will receive
consideration as community
development activities if they would
have been considered to have a primary
purpose of community development if
the census tract in which they were
located were still designated as
distressed or underserved.
§ ll.12(g)(4)(iii)–3: What activities
are considered to ‘‘revitalize or
stabilize’’ a distressed nonmetropolitan
middle-income geography, and how are
those activities evaluated?
A3. An activity revitalizes or
stabilizes a distressed nonmetropolitan
middle-income geography if it helps to
attract new, or retain existing,
businesses or residents. An activity will
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be presumed to revitalize or stabilize the
area if the activity is consistent with a
bona fide government revitalization or
stabilization plan. The Agencies
generally will consider all activities that
revitalize or stabilize a distressed
nonmetropolitan middle-income
geography, but will give greater weight
to those activities that are most
responsive to community needs,
including needs of low- or moderateincome individuals or neighborhoods.
Qualifying activities may include, for
example, providing financing to attract
a major new employer that will create
long-term job opportunities, including
for low- and moderate-income
individuals, and activities that provide
financing or other assistance for
essential infrastructure or facilities
necessary to attract or retain businesses
or residents. See Q&As
§ ll.12(g)(4)(i)–1 and § ll.12(h)–5.
§ ll.12(g)(4)(iii)–4: What activities
are considered to ‘‘revitalize or
stabilize’’ an underserved
nonmetropolitan middle-income
geography, and how are those activities
evaluated?
A4. The regulation provides that
activities revitalize or stabilize an
underserved nonmetropolitan middleincome geography if they help to meet
essential community needs, including
needs of low- or moderate-income
individuals. Activities such as financing
for the construction, expansion,
improvement, maintenance, or
operation of essential infrastructure or
facilities for health services, education,
public safety, public services, industrial
parks, or affordable housing, will be
evaluated under these criteria to
determine if they qualify for
revitalization or stabilization
consideration. Examples of the types of
projects that qualify as meeting essential
community needs, including needs of
low- or moderate-income individuals,
would be a new or expanded hospital
that serves the entire county, including
low- and moderate-income residents; an
industrial park for businesses whose
employees include low- or moderateincome individuals; a new or
rehabilitated sewer line that serves
community residents, including low- or
moderate-income residents; a mixedincome housing development that
includes affordable housing for low- and
moderate-income families; or a
renovated elementary school that serves
children from the community, including
children from low- and moderateincome families.
Other activities in the area, such as
financing a project to build a sewer line
spur that connects services to a middleor upper-income housing development
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while bypassing a low- or
moderate-income development that also
needs the sewer services, generally
would not qualify for revitalization or
stabilization consideration in
geographies designated as underserved.
However, if an underserved geography
is also designated as distressed or a
disaster area, additional activities may
be considered to revitalize or stabilize
the geography, as explained in Q&As
§ ll.12(g)(4)(ii)–2 and
§ ll.12(g)(4)(iii)–3.
§ ll.12(h) Community Development
Loan
§ ll.12(h)–1: What are examples of
community development loans?
A1. Examples of community
development loans include, but are not
limited to, loans to:
• Borrowers for affordable housing
rehabilitation and construction,
including construction and permanent
financing of multifamily rental property
serving low- and moderate-income
persons;
• Not-for-profit organizations serving
primarily low- and moderate-income
housing or other community
development needs;
• Borrowers to construct or
rehabilitate community facilities that
are located in low- and
moderate-income areas or that serve
primarily low- and moderate-income
individuals;
• Financial intermediaries including
Community Development Financial
Institutions (CDFIs), New Markets Tax
Credit-eligible Community Development
Entities, Community Development
Corporations (CDCs), minority- and
women-owned financial institutions,
community loan funds or pools, and
low-income or community development
credit unions that primarily lend or
facilitate lending to promote community
development;
• Local, state, and tribal governments
for community development activities;
• Borrowers to finance environmental
clean-up or redevelopment of an
industrial site as part of an effort to
revitalize the low- or moderate-income
community in which the property is
located; and
• Businesses, in an amount greater
than $1 million, when made as part of
the Small Business Administration’s
504 Certified Development Company
program.
The rehabilitation and construction of
affordable housing or community
facilities, referred to above, may include
the abatement or remediation of, or
other actions to correct, environmental
hazards, such as lead-based paint, that
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are present in the housing, facilities, or
site.
§ ll.12(h)–2: If a retail institution
that is not required to report under the
Home Mortgage Disclosure Act (HMDA)
makes affordable home mortgage loans
that would be HMDA-reportable home
mortgage loans if it were a reporting
institution, or if a small institution that
is not required to collect and report loan
data under the CRA makes small
business and small farm loans and
consumer loans that would be collected
and/or reported if the institution were a
large institution, may the institution
have these loans considered as
community development loans?
A2. No. Although small institutions
are not required to report or collect
information on small business and small
farm loans and consumer loans, and
some institutions are not required to
report information about their home
mortgage loans under HMDA, if these
institutions are retail institutions, the
agencies will consider in their CRA
evaluations the institutions’ originations
and purchases of loans that would have
been collected or reported as small
business, small farm, consumer or home
mortgage loans, had the institution been
a collecting and reporting institution
under the CRA or the HMDA. Therefore,
these loans will not be considered as
community development loans, unless
the small institution is an intermediate
small institution (see § ll.12(h)–3).
Multifamily dwelling loans, however,
may be considered as community
development loans as well as home
mortgage loans. See also Q&A
§ ll.42(b)(2)–2.
§ ll.12(h)–3: May an intermediate
small institution that is not subject to
HMDA reporting have home mortgage
loans considered as community
development loans? Similarly, may an
intermediate small institution have
small business and small farm loans
and consumer loans considered as
community development loans?
A3. Yes. In instances where
intermediate small institutions are not
required to report HMDA or small
business or small farm loans, these
loans may be considered, at the
institution’s option, as community
development loans, provided they meet
the regulatory definition of ‘‘community
development.’’ If small business or
small farm loan data have been reported
to the agencies to preserve the option to
be evaluated as a large institution, but
the institution ultimately chooses to be
evaluated under the intermediate small
institution examination standards, then
the institution would continue to have
the option to have such loans
considered as community development
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loans. However, if the institution opts to
be evaluated under the lending,
investment, and service tests applicable
to large institutions, it may not choose
to have home mortgage, small business,
small farm, or consumer loans
considered as community development
loans.
Loans other than multifamily
dwelling loans may not be considered
under both the lending test and the
community development test for
intermediate small institutions. Thus, if
an institution elects to have certain
loans considered under the community
development test, those loans may not
also be considered under the lending
test, and would be excluded from the
lending test analysis.
Intermediate small institutions may
choose individual loans within their
portfolio for community development
consideration. Examiners will evaluate
an intermediate small institution’s
community development activities
within the context of the responsiveness
of the activity to the community
development needs of the institution’s
assessment area.
§ ll.12(h)–4: Do secured credit
cards or other credit card programs
targeted to low- or moderate-income
individuals qualify as community
development loans?
A4. No. Credit cards issued to low- or
moderate-income individuals for
household, family, or other personal
expenditures, whether as part of a
program targeted to such individuals or
otherwise, do not qualify as community
development loans because they do not
have as their primary purpose any of the
activities included in the definition of
‘‘community development.’’
§ ll.12(h)–5: The regulation
indicates that community development
includes ‘‘activities that revitalize or
stabilize low- or moderate-income
geographies.’’ Do all loans in a low- to
moderate-income geography have a
stabilizing effect?
A5. No. Some loans may provide only
indirect or short-term benefits to low- or
moderate-income individuals in a lowor moderate-income geography. These
loans are not considered to have a
community development purpose. For
example, a loan for upper-income
housing in a low- or moderate-income
area is not considered to have a
community development purpose
simply because of the indirect benefit to
low- or moderate-income persons from
construction jobs or the increase in the
local tax base that supports enhanced
services to low- and moderate-income
area residents. On the other hand, a loan
for an anchor business in a low- or
moderate-income area (or a nearby area)
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that employs or serves residents of the
area and, thus, stabilizes the area, may
be considered to have a community
development purpose. For example, in a
low-income area, a loan for a pharmacy
that employs and serves residents of the
area promotes community development.
§ ll.12(h)–6: Must there be some
immediate or direct benefit to the
institution’s assessment area(s) to
satisfy the regulations’ requirement that
qualified investments and community
development loans or services benefit an
institution’s assessment area(s) or a
broader statewide or regional area that
includes the institution’s assessment
area(s)?
A6. No. The regulations recognize that
community development organizations
and programs are efficient and effective
ways for institutions to promote
community development. These
organizations and programs often
operate on a statewide or even
multistate basis. Therefore, an
institution’s activity is considered a
community development loan or service
or a qualified investment if it supports
an organization or activity that covers
an area that is larger than, but includes,
the institution’s assessment area(s). The
institution’s assessment area(s) need not
receive an immediate or direct benefit
from the institution’s specific
participation in the broader organization
or activity, provided that the purpose,
mandate, or function of the organization
or activity includes serving geographies
or individuals located within the
institution’s assessment area(s).
In addition, a retail institution that,
considering its performance context, has
adequately addressed the community
development needs of its assessment
area(s) will receive consideration for
certain other community development
activities. These community
development activities must benefit
geographies or individuals located
somewhere within a broader statewide
or regional area that includes the
institution’s assessment area(s).
Examiners will consider these activities
even if they will not benefit the
institution’s assessment area(s).
§ ll.12(h)–7: What is meant by the
term ‘‘regional area’’?
A7. A ‘‘regional area’’ may be as large
as a multistate area. For example, the
‘‘mid-Atlantic states’’ may comprise a
regional area.
Community development loans and
services and qualified investments to
statewide or regional organizations that
have a bona fide purpose, mandate, or
function that includes serving the
geographies or individuals within the
institution’s assessment area(s) will be
considered as addressing assessment
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area needs. When examiners evaluate
community development loans and
services and qualified investments that
benefit a regional area that includes the
institution’s assessment area(s), they
will consider the institution’s
performance context as well as the size
of the regional area and the actual or
potential benefit to the institution’s
assessment area(s). With larger regional
areas, benefit to the institution’s
assessment area(s) may be diffused and,
thus, less responsive to assessment area
needs.
In addition, as long as an institution
has adequately addressed the
community development needs of its
assessment area(s), it will also receive
consideration for community
development activities that benefit
geographies or individuals located
somewhere within the broader
statewide or regional area that includes
the institution’s assessment area(s), even
if those activities do not benefit its
assessment area(s).
§ ll.12(h)–8: What is meant by the
term ‘‘primary purpose’’ as that term is
used to define what constitutes a
community development loan, a
qualified investment or a community
development service?
A8. A loan, investment or service has
as its primary purpose community
development when it is designed for the
express purpose of revitalizing or
stabilizing low- or moderate-income
areas, designated disaster areas, or
underserved or distressed
nonmetropolitan middle-income areas,
providing affordable housing for, or
community services targeted to, low- or
moderate-income persons, or promoting
economic development by financing
small businesses and farms that meet
the requirements set forth in 12 CFR
ll.12(g). To determine whether an
activity is designed for an express
community development purpose, the
agencies apply one of two approaches.
First, if a majority of the dollars or
beneficiaries of the activity are
identifiable to one or more of the
enumerated community development
purposes, then the activity will be
considered to possess the requisite
primary purpose. Alternatively, where
the measurable portion of any benefit
bestowed or dollars applied to the
community development purpose is less
than a majority of the entire activity’s
benefits or dollar value, then the activity
may still be considered to possess the
requisite primary purpose if (1) The
express, bona fide intent of the activity,
as stated, for example, in a prospectus,
loan proposal, or community action
plan, is primarily one or more of the
enumerated community development
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purposes; (2) the activity is specifically
structured (given any relevant market or
legal constraints or performance context
factors) to achieve the expressed
community development purpose; and
(3) the activity accomplishes, or is
reasonably certain to accomplish, the
community development purpose
involved. The fact that an activity
provides indirect or short-term benefits
to low- or moderate-income persons
does not make the activity community
development, nor does the mere
presence of such indirect or short-term
benefits constitute a primary purpose of
community development. Financial
institutions that want examiners to
consider certain activities under either
approach should be prepared to
demonstrate the activities’
qualifications.
§ ll.12(i) Community Development
Service
§ ll.12(i)–1: In addition to meeting
the definition of ‘‘community
development’’ in the regulation,
community development services must
also be related to the provision of
financial services. What is meant by
‘‘provision of financial services’’?
A1. Providing financial services
means providing services of the type
generally provided by the financial
services industry. Providing financial
services often involves informing
community members about how to get
or use credit or otherwise providing
credit services or information to the
community. For example, service on the
board of directors of an organization
that promotes credit availability or
finances affordable housing is related to
the provision of financial services.
Providing technical assistance about
financial services to community-based
groups, local or tribal government
agencies, or intermediaries that help to
meet the credit needs of low- and
moderate-income individuals or small
businesses and farms is also providing
financial services. By contrast, activities
that do not take advantage of the
employees’ financial expertise, such as
neighborhood cleanups, do not involve
the provision of financial services.
§ ll.12(i)–2: Are personal charitable
activities provided by an institution’s
employees or directors outside the
ordinary course of their employment
considered community development
services?
A2. No. Services must be provided as
a representative of the institution. For
example, if a financial institution’s
director, on her own time and not as a
representative of the institution,
volunteers one evening a week at a local
community development corporation’s
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financial counseling program, the
institution may not consider this
activity a community development
service.
§ ll.12(i)–3: What are examples of
community development services?
A3. Examples of community
development services include, but are
not limited to, the following:
• Providing financial services to lowand moderate-income individuals
through branches and other facilities
located in low- and moderate-income
areas, unless the provision of such
services has been considered in the
evaluation of an institution’s retail
banking services under 12 CFR
ll.24(d);
• Increasing access to financial
services by opening or maintaining
branches or other facilities that help to
revitalize or stabilize a low- or
moderate-income geography, a
designated disaster area, or a distressed
or underserved nonmetropolitan
middle-income geography, unless the
opening or maintaining of such
branches or other facilities has been
considered in the evaluation of the
institution’s retail banking services
under 12 CFR ll.24(d);
• Providing technical assistance on
financial matters to nonprofit, tribal, or
government organizations serving lowand moderate-income housing or
economic revitalization and
development needs;
• Providing technical assistance on
financial matters to small businesses or
community development organizations,
including organizations and individuals
who apply for loans or grants under the
Federal Home Loan Banks’ Affordable
Housing Program;
• Lending employees to provide
financial services for organizations
facilitating affordable housing
construction and rehabilitation or
development of affordable housing;
• Providing credit counseling, homebuyer and home-maintenance
counseling, financial planning or other
financial services education to promote
community development and affordable
housing, including credit counseling to
assist low- or moderate-income
borrowers in avoiding foreclosure on
their homes;
• Establishing school savings
programs or developing or teaching
financial education or literacy curricula
for low- or moderate-income
individuals;
• Providing electronic benefits
transfer and point of sale terminal
systems to improve access to financial
services, such as by decreasing costs, for
low- or moderate-income individuals;
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• Providing international remittance
services that increase access to financial
services by low- and moderate-income
persons (for example, by offering
reasonably priced international
remittance services in connection with
a low-cost account);
• Providing other financial services
with the primary purpose of community
development, such as low-cost savings
or checking accounts, including
‘‘Electronic Transfer Accounts’’
provided pursuant to the Debt
Collection Improvement Act of 1996,
individual development accounts
(IDAs), or free or low-cost government,
payroll, or other check cashing services,
that increase access to financial services
for low- or moderate-income
individuals; and
• Providing foreclosure prevention
programs to low- or moderate-income
homeowners who are facing foreclosure
on their primary residence with the
objective of providing affordable,
sustainable, long-term loan
modifications and restructurings.
Examples of technical assistance
activities that might be provided to
community development organizations
include:
• Serving on a loan review
committee;
• Developing loan application and
underwriting standards;
• Developing loan processing
systems;
• Developing secondary market
vehicles or programs;
• Assisting in marketing financial
services, including development of
advertising and promotions,
publications, workshops and
conferences;
• Furnishing financial services
training for staff and management;
• Contributing accounting/
bookkeeping services; and
• Assisting in fund raising, including
soliciting or arranging investments.
§ ll.12(j) Consumer Loan
§ ll.12(j)–1: Are home equity loans
considered ‘‘consumer loans’’?
A1. Home equity loans made for
purposes other than home purchase,
home improvement or refinancing home
purchase or home improvement loans
are consumer loans if they are extended
to one or more individuals for
household, family, or other personal
expenditures.
§ ll.12(j)–2: May a home equity line
of credit be considered a ‘‘consumer
loan’’ even if part of the line is for home
improvement purposes?
A2. If the predominant purpose of the
line is home improvement, the line may
only be reported under HMDA and may
not be considered a consumer loan.
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However, the full amount of the line
may be considered a ‘‘consumer loan’’ if
its predominant purpose is for
household, family, or other personal
expenditures, and to a lesser extent
home improvement, and the full amount
of the line has not been reported under
HMDA. This is the case even though
there may be ‘‘double counting’’ because
part of the line may also have been
reported under HMDA.
§ ll.12(j)–3: How should an
institution collect or report information
on loans the proceeds of which will be
used for multiple purposes?
A3. If an institution makes a single
loan or provides a line of credit to a
customer to be used for both consumer
and small business purposes, consistent
with the Call Report and TFR
instructions, the institution should
determine the major (predominant)
component of the loan or the credit line
and collect or report the entire loan or
credit line in accordance with the
regulation’s specifications for that loan
type.
§ ll.12(l) Home Mortgage Loan
§ ll.12(l)–1: Does the term ‘‘home
mortgage loan’’ include loans other than
‘‘home purchase loans’’?
A1. Yes. ‘‘Home mortgage loan’’
includes ‘‘home improvement loan,’’
‘‘home purchase loan,’’ and
‘‘refinancing,’’ as defined in the HMDA
regulation, Regulation C, 12 CFR part
203. This definition also includes
multifamily (five-or-more families)
dwelling loans, and loans for the
purchase of manufactured homes. See
also Q&A § ll.22(a)(2)–7.
§ ll.12(l)–2: Some financial
institutions broker home mortgage
loans. They typically take the borrower’s
application and perform other
settlement activities; however, they do
not make the credit decision. The broker
institutions may also initially fund these
mortgage loans, then immediately
assign them to another lender. Because
the broker institution does not make the
credit decision, under Regulation C
(HMDA), they do not record the loans on
their HMDA–LARs, even if they fund the
loans. May an institution receive any
consideration under CRA for its home
mortgage loan brokerage activities?
A2. Yes. A financial institution that
funds home mortgage loans but
immediately assigns the loans to the
lender that made the credit decisions
may present information about these
loans to examiners for consideration
under the lending test as ‘‘other loan
data.’’ Under Regulation C, the broker
institution does not record the loans on
its HMDA–LAR because it does not
make the credit decisions, even if it
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funds the loans. An institution electing
to have these home mortgage loans
considered must maintain information
about all of the home mortgage loans
that it has funded in this way.
Examiners will consider these other
loan data using the same criteria by
which home mortgage loans originated
or purchased by an institution are
evaluated.
Institutions that do not provide
funding but merely take applications
and provide settlement services for
another lender that makes the credit
decisions will receive consideration for
this service as a retail banking service.
Examiners will consider an institution’s
mortgage brokerage services when
evaluating the range of services
provided to low-, moderate-, middleand upper-income geographies and the
degree to which the services are tailored
to meet the needs of those geographies.
Alternatively, an institution’s mortgage
brokerage service may be considered a
community development service if the
primary purpose of the service is
community development. An institution
wishing to have its mortgage brokerage
service considered as a community
development service must provide
sufficient information to substantiate
that its primary purpose is community
development and to establish the extent
of the services provided.
§ ll.12(m) Income Level
§ ll.12(m)–1: Where do institutions
find income level data for geographies
and individuals?
A1. The income levels for
geographies, i.e., census tracts, are
derived from Census Bureau
information and are updated
approximately every ten years. The
income levels for individuals are
derived from information calculated by
the Department of Housing and Urban
Development (HUD) and updated
annually.
Institutions may obtain 2000
geography income information and the
annually updated HUD median family
incomes for metropolitan statistical
areas (MSAs) and statewide
nonmetropolitan areas by accessing the
Federal Financial Institution
Examination Council’s (FFIEC’s) Web
site at https://www.ffiec.gov/cra or by
calling the FFIEC’s CRA Assistance Line
at (202) 872–7584.
§ ll.12(n) Limited Purpose Institution
§ ll.12(n)–1: What constitutes a
‘‘narrow product line’’ in the definition
of ‘‘limited purpose institution’’?
A1. An institution offers a narrow
product line by limiting its lending
activities to a product line other than a
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traditional retail product line required
to be evaluated under the lending test
(i.e., home mortgage, small business,
and small farm loans). Thus, an
institution engaged only in making
credit card or motor vehicle loans offers
a narrow product line, while an
institution limiting its lending activities
to home mortgages is not offering a
narrow product line.
§ ll.12(n)–2: What factors will the
agencies consider to determine whether
an institution that, if limited purpose,
makes loans outside a narrow product
line, or, if wholesale, engages in retail
lending, will lose its limited purpose or
wholesale designation because of too
much other lending?
A2. Wholesale institutions may
engage in some retail lending without
losing their designation if this activity is
incidental and done on an
accommodation basis. Similarly, limited
purpose institutions continue to meet
the narrow product line requirement if
they provide other types of loans on an
infrequent basis. In reviewing other
lending activities by these institutions,
the agencies will consider the following
factors:
• Is the retail lending provided as an
incident to the institution’s wholesale
lending?
• Are the retail loans provided as an
accommodation to the institution’s
wholesale customers?
• Are the other types of loans made
only infrequently to the limited purpose
institution’s customers?
• Does only an insignificant portion
of the institution’s total assets and
income result from the other lending?
• How significant a role does the
institution play in providing that type(s)
of loan(s) in the institution’s assessment
area(s)?
• Does the institution hold itself out
as offering that type(s) of loan(s)?
• Does the lending test or the
community development test present a
more accurate picture of the
institution’s CRA performance?
§ ll.12(n)–3: Do ‘‘niche
institutions’’ qualify as limited purpose
(or wholesale) institutions?
A3. Generally, no. Institutions that are
in the business of lending to the public,
but specialize in certain types of retail
loans (for example, home mortgage or
small business loans) to certain types of
borrowers (for example, to high-end
income level customers or to
corporations or partnerships of licensed
professional practitioners) (‘‘niche
institutions’’) generally would not
qualify as limited purpose (or
wholesale) institutions.
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§ ll.12(t) Qualified Investment
§ ll.12(t)–1: Does the CRA
regulation provide authority for
institutions to make investments?
A1. No. The CRA regulation does not
provide authority for institutions to
make investments that are not otherwise
allowed by Federal law.
§ ll.12(t)–2: Are mortgage-backed
securities or municipal bonds ‘‘qualified
investments’’?
A2. As a general rule, mortgagebacked securities and municipal bonds
are not qualified investments because
they do not have as their primary
purpose community development, as
defined in the CRA regulations.
Nonetheless, mortgage-backed securities
or municipal bonds designed primarily
to finance community development
generally are qualified investments.
Municipal bonds or other securities
with a primary purpose of community
development need not be housingrelated. For example, a bond to fund a
community facility or park or to provide
sewage services as part of a plan to
redevelop a low-income neighborhood
is a qualified investment. Certain
municipal bonds in underserved
nonmetropolitan middle-income
geographies may also be qualified
investments. See Q&A
§ ll.12(g)(4)(iii)–4. Housing-related
bonds or securities must primarily
address affordable housing (including
multifamily rental housing) needs of
low- or moderate-income individuals in
order to qualify. See also Q&A
§ ll.23(b)–2.
§ ll.12(t)–3: Are Federal Home
Loan Bank stocks or unpaid dividends
and membership reserves with the
Federal Reserve Banks ‘‘qualified
investments’’?
A3. No. Federal Home Loan Bank
(FHLB) stocks or unpaid dividends, and
membership reserves with the Federal
Reserve Banks do not have a sufficient
connection to community development
to be qualified investments. However,
FHLB member institutions may receive
CRA consideration as a community
development service for technical
assistance they provide on behalf of
applicants and recipients of funding
from the FHLB’s Affordable Housing
Program. See Q&A § ll.12(i)–3.
§ ll.12(t)–4: What are examples of
qualified investments?
A4. Examples of qualified
investments include, but are not limited
to, investments, grants, deposits, or
shares in or to:
• Financial intermediaries (including
Community Development Financial
Institutions (CDFIs), New Markets Tax
Credit-eligible Community Development
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Entities, Community Development
Corporations (CDCs), minority- and
women-owned financial institutions,
community loan funds, and low-income
or community development credit
unions) that primarily lend or facilitate
lending in low- and moderate-income
areas or to low- and moderate-income
individuals in order to promote
community development, such as a
CDFI that promotes economic
development on an Indian reservation;
• Organizations engaged in affordable
housing rehabilitation and construction,
including multifamily rental housing;
• Organizations, including, for
example, Small Business Investment
Companies (SBICs), specialized SBICs,
and Rural Business Investment
Companies (RBICs) that promote
economic development by financing
small businesses;
• Community development venture
capital companies that promote
economic development by financing
small businesses;
• Facilities that promote community
development by providing community
services for low- and moderate-income
individuals, such as youth programs,
homeless centers, soup kitchens, health
care facilities, battered women’s centers,
and alcohol and drug recovery centers;
• Projects eligible for low-income
housing tax credits;
• State and municipal obligations,
such as revenue bonds, that specifically
support affordable housing or other
community development;
• Not-for-profit organizations serving
low- and moderate-income housing or
other community development needs,
such as counseling for credit, homeownership, home maintenance, and
other financial literacy programs; and
• Organizations supporting activities
essential to the capacity of low- and
moderate-income individuals or
geographies to utilize credit or to
sustain economic development, such as,
for example, day care operations and job
training programs that enable low- or
moderate-income individuals to work.
See also Q&As § ll.12(g)(4)(ii)–2;
§ ll.12(g)(4)(iii)–3; § ll.12(g)(4)(iii)–
4.
§ ll.12(t)–5: Will an institution
receive consideration for charitable
contributions as ‘‘qualified
investments’’?
A5. Yes, provided they have as their
primary purpose community
development as defined in the
regulations. A charitable contribution,
whether in cash or an in-kind
contribution of property, is included in
the term ‘‘grant.’’ A qualified investment
is not disqualified because an
institution receives favorable treatment
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for it (for example, as a tax deduction
or credit) under the Internal Revenue
Code.
§ ll.12(t)–6: An institution makes or
participates in a community
development loan. The institution
provided the loan at below-market
interest rates or ‘‘bought down’’ the
interest rate to the borrower. Is the lost
income resulting from the lower interest
rate or buy-down a qualified
investment?
A6. No. The agencies will, however,
consider the responsiveness,
innovativeness, and complexity of the
community development loan within
the bounds of safe and sound banking
practices.
§ ll.12(t)–7: Will the agencies
consider as a qualified investment the
wages or other compensation of an
employee or director who provides
assistance to a community development
organization on behalf of the
institution?
A7. No. However, the agencies will
consider donated labor of employees or
directors of a financial institution as a
community development service if the
activity meets the regulatory definition
of ‘‘community development service.’’
§ ll.12(t)–8: When evaluating a
qualified investment, what
consideration will be given for priorperiod investments?
A8. When evaluating an institution’s
qualified investment record, examiners
will consider investments that were
made prior to the current examination,
but that are still outstanding. Qualitative
factors will affect the weighting given to
both current period and outstanding
prior-period qualified investments. For
example, a prior-period outstanding
investment with a multi-year impact
that addresses assessment area
community development needs may
receive more consideration than a
current period investment of a
comparable amount that is less
responsive to area community
development needs.
§ ll.12(u) Small Institution
§ ll.12(u)–1: How are Federal and
State branch assets of a foreign bank
calculated for purposes of the CRA?
A1. A Federal or State branch of a
foreign bank is considered a small
institution if the Federal or State branch
has assets less than the asset threshold
delineated in 12 CFR ll.12(u)(1) for
small institutions.
§ ll.12(u)(2) Small Institution
Adjustment
§ ll.12(u)(2)–1: How often will the
asset size thresholds for small
institutions and intermediate small
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institutions be changed, and how will
these adjustments be communicated?
A1. The asset size thresholds for
‘‘small institutions’’ and ‘‘intermediate
small institutions’’ will be adjusted
annually based on changes to the
Consumer Price Index. More
specifically, the dollar thresholds will
be adjusted annually based on the yearto-year change in the average of the
Consumer Price Index for Urban Wage
Earners and Clerical Workers, not
seasonally adjusted for each twelvemonth period ending in November, with
rounding to the nearest million. Any
changes in the asset size thresholds will
be published in the Federal Register.
Historical and current asset-size
threshold information may be found on
the FFIEC’s Web site at https://
www.ffiec.gov/cra.
§ .12(v) Small Business Loan
§ .12(v)–1: Are loans to nonprofit
organizations considered small business
loans or are they considered community
development loans?
A1. To be considered a small business
loan, a loan must meet the definition of
‘‘loan to small business’’ in the
instructions in the ‘‘Consolidated
Reports of Conditions and Income’’ (Call
Report) and ‘‘Thrift Financial Report’’
(TFR). In general, a loan to a nonprofit
organization, for business or farm
purposes, where the loan is secured by
nonfarm nonresidential property and
the original amount of the loan is $1
million or less, if a business loan, or
$500,000 or less, if a farm loan, would
be reported in the Call Report and TFR
as a small business or small farm loan.
If a loan to a nonprofit organization is
reportable as a small business or small
farm loan, it cannot also be considered
as a community development loan,
except by a wholesale or limited
purpose institution. Loans to nonprofit
organizations that are not small business
or small farm loans for Call Report and
TFR purposes may be considered as
community development loans if they
meet the regulatory definition of
‘‘community development.’’
§ .12(v)–2: Are loans secured by
commercial real estate considered small
business loans?
A2. Yes, depending on their principal
amount. Small business loans include
loans secured by ‘‘nonfarm
nonresidential properties,’’ as defined in
the Call Report and TFR, in amounts of
$1 million or less.
§ .12(v)–3: Are loans secured by
nonfarm residential real estate to
finance small businesses ‘‘small
business loans’’?
A3. Applicable to banks filing Call
Reports: Typically not. Loans secured
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by nonfarm residential real estate that
are used to finance small businesses are
not included as ‘‘small business’’ loans
for Call Report purposes unless the
security interest in the nonfarm
residential real estate is taken only as an
abundance of caution. (See Call Report
Glossary definition of ‘‘Loan Secured by
Real Estate.’’) The agencies recognize
that many small businesses are financed
by loans that would not have been made
or would have been made on less
favorable terms had they not been
secured by residential real estate. If
these loans promote community
development, as defined in the
regulation, they may be considered as
community development loans.
Otherwise, at an institution’s option, the
institution may collect and maintain
data separately concerning these loans
and request that the data be considered
in its CRA evaluation as ‘‘Other Secured
Lines/Loans for Purposes of Small
Business.’’ See also Q&A
§ ll.22(a)(2)–7.
Applicable to institutions that file
TFRs: Possibly, depending how the loan
is classified for TFR purposes. Loans
secured by nonfarm residential real
estate to finance small businesses may
be included as small business loans
only if they are reported on the TFR as
nonmortgage, commercial loans. (See
TFR Q&A No. 62.) Otherwise, loans that
meet the definition of mortgage loans,
for TFR reporting purposes, may be
classified as mortgage loans.
§ .12(v)–4: Are credit cards issued to
small businesses considered ‘‘small
business loans’’?
A4. Credit cards issued to a small
business or to individuals to be used,
with the institution’s knowledge, as
business accounts are small business
loans if they meet the definitional
requirements in the Call Report or TFR
instructions.
§ ll.12(x) Wholesale Institution
§ ll.12(x)–1: What factors will the
agencies consider in determining
whether an institution is in the business
of extending home mortgage, small
business, small farm, or consumer loans
to retail customers?
A1. The agencies will consider
whether:
• The institution holds itself out to
the retail public as providing such
loans; and
• The institution’s revenues from
extending such loans are significant
when compared to its overall
operations, including off-balance sheet
activities.
A wholesale institution may make
some retail loans without losing its
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wholesale designation as described
above in Q&A § ll.12(n)–2.
§ ll.21—Performance Tests,
Standards, and Ratings, in General
§ ll.21(a) Performance Tests and
Standards
§ ll.21(a)–1: How will examiners
apply the performance criteria?
A1. Examiners will apply the
performance criteria reasonably and
fairly, in accord with the regulations,
the examination procedures, and this
guidance. In doing so, examiners will
disregard efforts by an institution to
manipulate business operations or
present information in an artificial light
that does not accurately reflect an
institution’s overall record of lending
performance.
§ ll.21(a)–2: Are all community
development activities weighted equally
by examiners?
A2. No. Examiners will consider the
responsiveness to credit and community
development needs, as well as the
innovativeness and complexity, if
applicable, of an institution’s
community development lending,
qualified investments, and community
development services. These criteria
include consideration of the degree to
which they serve as a catalyst for other
community development activities. The
criteria are designed to add a qualitative
element to the evaluation of an
institution’s performance.
(‘‘Innovativeness’’ and ‘‘complexity’’ are
not factors in the community
development test applicable to
intermediate small institutions.)
§ ll.21(b) Performance Context
§ ll.21(b)–1: What is the
performance context?
A1. The performance context is a
broad range of economic, demographic,
and institution- and community-specific
information that an examiner reviews to
understand the context in which an
institution’s record of performance
should be evaluated. The agencies will
provide examiners with some of this
information. The performance context is
not a formal assessment of community
credit needs.
§ ll.21(b)(2) Information Maintained
by the Institution or Obtained From
Community Contacts
§ ll.21(b)(2)–1: Will examiners
consider performance context
information provided by institutions?
A1. Yes. An institution may provide
examiners with any information it
deems relevant, including information
on the lending, investment, and service
opportunities in its assessment area(s).
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This information may include data on
the business opportunities addressed by
lenders not subject to the CRA.
Institutions are not required, however,
to prepare a formal needs assessment. If
an institution provides information to
examiners, the agencies will not expect
information other than what the
institution normally would develop to
prepare a business plan or to identify
potential markets and customers,
including low- and moderate-income
persons and geographies in its
assessment area(s). The agencies will
not evaluate an institution’s efforts to
ascertain community credit needs or
rate an institution on the quality of any
information it provides.
§ ll.21(b)(2)–2: Will examiners
conduct community contact interviews
as part of the examination process?
A2. Yes. Examiners will consider
information obtained from interviews
with local community, civic, and
government leaders. These interviews
provide examiners with knowledge
regarding the local community, its
economic base, and community
development initiatives. To ensure that
information from local leaders is
considered—particularly in areas where
the number of potential contacts may be
limited—examiners may use
information obtained through an
interview with a single community
contact for examinations of more than
one institution in a given market. In
addition, the agencies may consider
information obtained from interviews
conducted by other agency staff and by
the other agencies. In order to augment
contacts previously used by the agencies
and foster a wider array of contacts, the
agencies may share community contact
information.
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§ ll.21(b)(4) Institutional Capacity
and Constraints
§ ll.21(b)(4)–1: Will examiners
consider factors outside of an
institution’s control that prevent it from
engaging in certain activities?
A1. Yes. Examiners will take into
account statutory and supervisory
limitations on an institution’s ability to
engage in any lending, investment, and
service activities. For example, a savings
association that has made few or no
qualified investments due to its limited
investment authority may still receive a
low satisfactory rating under the
investment test if it has a strong lending
record.
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§ ll.21(b)(5) Institution’s Past
Performance and the Performance of
Similarly Situated Lenders
§ ll.21(b)(5)–1: Can an institution’s
assigned rating be adversely affected by
poor past performance?
A1. Yes. The agencies will consider
an institution’s past performance in its
overall evaluation. For example, an
institution that received a rating of
‘‘needs to improve’’ in the past may
receive a rating of ‘‘substantial
noncompliance’’ if its performance has
not improved.
§ ll.21(b)(5)—2: 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 upperincome geographies. This analysis, as
well as other analyses, may be used, for
example, where groups of contiguous
geographies within an institution’s
assessment area(s) exhibit abnormally
low penetration. In this regard, the
performance of similarly situated
lenders may be analyzed if such an
analysis would provide accurate insight
into the institution’s lack of
performance in those areas. The
regulation does not require the use of a
specific type of analysis under these
circumstances. Moreover, no ratio
developed from any type of analysis is
linked to any lending test rating.
§ ll.22—Lending Test
§ ll.22(a) Scope of Test
§ ll.22(a)–1: 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
likely to be responsive in helping to
meet the credit needs of many
communities. These activities include:
• Providing loan programs that
include a financial education
component about how to avoid lending
activities that may be abusive or
otherwise unsuitable;
• Establishing loan programs that
provide small, unsecured consumer
loans in a safe and sound manner (i.e.,
based on the borrower’s ability to repay)
and with reasonable terms;
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• Offering lending programs, which
feature reporting to consumer reporting
agencies, that transition borrowers from
loans with higher interest rates and fees
(based on credit risk) to lower-cost
loans, consistent with safe and sound
lending practices. Reporting to
consumer reporting agencies allows
borrowers accessing these programs the
opportunity to improve their credit
histories and thereby improve their
access to competitive credit products;
• Establishing loan programs with the
objective of providing affordable,
sustainable, long-term relief, for
example, through loan refinancings,
restructures, or modifications, to
homeowners who are facing foreclosure
on their primary residences.
Examiners may consider favorably such
lending activities, which have features
augmenting the success and
effectiveness of the small, intermediate
small, or large institution’s lending
programs.
§ ll.22(a)(1) Types of Loans
Considered
§ ll.22(a)(1)–1: 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.
§ ll.22(a)(1)–2: 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 does. However, if consumer
loans constitute a substantial majority of
the institution’s business, the agencies
will evaluate them even if the
institution does not so elect. The
agencies interpret ‘‘substantial majority’’
to be so significant a portion of the
institution’s lending activity by number
and dollar volume of loans that the
lending test evaluation would not
meaningfully reflect its lending
performance if consumer loans were
excluded.
§ ll.22(a)(2) Loan Originations and
Purchases/Other Loan Data
§ ll.22(a)(2)–1: 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,
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regardless of examination type.
Commitments must be legally binding
between an institution and a borrower
in order to be considered. Information
about lending commitments will be
used by examiners to enhance their
understanding of an institution’s
performance, but will be evaluated
separately from the loans.
§ ll.22(a)(2)–2: 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.
§ ll.22(a)(2)–3: May a financial
institution receive consideration under
CRA for home mortgage loan
modification, extension, and
consolidation agreements (MECAs), 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 part 203?
A3. Yes. In some states, MECAs,
which are not considered loan
refinancings because the existing loan
obligations are not satisfied and
replaced, are common. Although these
transactions are not considered to be
purchases or refinancings, as those
terms have been interpreted under CRA,
they do achieve the same results. A
small, intermediate small, or large
institution may present information
about its MECA activities with respect
to home mortgages to examiners for
consideration under the lending test as
‘‘other loan data.’’
§ ll.22(a)(2)–4: In addition to
MECAs, 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 by nonfarm
residential real estate, not taken as an
abundance of caution, that are used to
finance small businesses or small farms
and that are not reported as small
business/small farm loans or reported
under HMDA;
• Loans that do not have a primary
purpose of community development,
but where a certain amount or
percentage of units is set aside for
affordable housing; and
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• An increase to a small business or
small farm line of credit if the increase
would cause the total line of credit to
exceed $1 million, in the case of a small
business line, or $500,000, in the case
of a small farm line.
§ ll.22(a)(2)–5: 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 not such loans
are guaranteed.
§ ll.22(a)(2)–6: Do institutions
receive consideration for purchasing
loan participations?
A6. Yes. Examiners will consider the
amount of loan participations purchased
when evaluating 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, regardless of examination
type. As with other loan purchases,
examiners will evaluate whether
participations in loan purchased, which
have been sold and purchased a number
of times, artificially inflate CRA
performance. See, e.g., § ll.21(a)–1.
§ ll.22(a)(2)–7: How are
refinancings of small business loans,
which are secured by a one-to-four
family residence and that have been
reported under HMDA as a refinancing,
evaluated under CRA?
A7. For banks subject to the Call
Report instructions: A loan of $1 million
or less with a business purpose that is
secured by a one-to-four family
residence is considered a small business
loan for CRA purposes only if the
security interest in the residential
property was taken as an abundance of
caution and where the terms have not
been made more favorable than they
would have been in the absence of the
lien. (See Call Report Glossary
definition of ‘‘Loan Secured by Real
Estate.’’) If this same loan is refinanced
and the new loan is also secured by a
one-to-four family residence, but only
through an abundance of caution, this
loan is reported not only as a
refinancing under HMDA, but also as a
small business loan under CRA. (Note
that small farm loans are similarly
treated.)
It is not anticipated that ‘‘doublereported’’ loans will be so numerous as
to affect the typical institution’s CRA
rating. In the event that an institution
reports a significant number or amount
of loans as both home mortgage and
small business loans, examiners will
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517
consider that overlap in evaluating the
institution’s performance and generally
will consider the ‘‘double-reported’’
loans as small business loans for CRA
consideration.
The origination of a small business or
small farm loan that is secured by a oneto-four family residence is not
reportable under HMDA, unless the
purpose of the loan is home purchase or
home improvement. Nor is the loan
reported as a small business or small
farm loan if the security interest is not
taken merely as an abundance of
caution. Any such loan may be provided
to examiners as ‘‘other loan data’’
(‘‘Other Secured Lines/Loans for
Purposes of Small Business’’) for
consideration during a CRA evaluation.
See Q&A § ll.12(v)–3. The
refinancings of such loans would be
reported under HMDA.
For savings associations subject to the
Thrift Financial Reporting instructions:
A loan of $1 million or less with a
business purpose secured by a one-tofour family residence is considered a
small business loan for CRA purposes if
it is reported as a small business loan
for TFR purposes and was not reported
on the TFR as a mortgage loan (TFR
Instructions for Commercial Loans:
Secured). If this same loan is refinanced
and the new loan is also secured by a
one-to-four family residence, and was
not reported for TFR purposes as a
mortgage loan, this loan is reported not
only as a refinancing for HMDA, but is
also reported as a small business loan
under the TFR and CRA. The
origination of a small business or small
farm loan that is secured by a one-tofour family residence is not reportable
under HMDA, unless the purpose of the
loan is home purchase or home
improvement. Nor is the loan reported
as small business or small farm if it was
reported as a mortgage on the TFR
report.
OTS does not anticipate that ‘‘doublereported’’ loans will be so numerous as
to affect the typical institution’s CRA
rating. In the event that an institution
reports a significant number or amount
of loans as both home mortgage and
small business loans, examiners will
consider that overlap in evaluating the
institution’s performance and generally
will consider the ‘‘double-reported’’
loans as small business loans for CRA
consideration.
The origination of a small business or
small farm loan that is secured by a oneto-four family residence should be
reported in accordance with Q&A
§ ll.12(v)–3. The refinancings of such
loans would be reported under HMDA.
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§ ll.22(b)(1) Lending Activity
§ ll.22(b)(1)–1: How will the
agencies apply the lending activity
criterion to discourage an institution
from originating loans that are viewed
favorably under CRA in the institution
itself and referring other loans, which
are not viewed as favorably, for
origination by an affiliate?
A1. Examiners will review closely
institutions with (1) a small number and
amount of home mortgage loans with an
unusually good distribution among lowand moderate-income areas and lowand moderate-income borrowers and (2)
a policy of referring most, but not all, of
their home mortgage loans to affiliated
institutions. If an institution is making
loans mostly to low- and moderateincome individuals and areas and
referring the rest of the loan applicants
to an affiliate for the purpose of
receiving a favorable CRA rating,
examiners may conclude that the
institution’s lending activity is not
satisfactory because it has
inappropriately attempted to influence
the rating. In evaluating an institution’s
lending, examiners will consider
legitimate business reasons for the
allocation of the lending activity.
§ ll.22(b)(2) & (3) Geographic
Distribution and Borrower
Characteristics
§ ll.22(b)(2) & (3)–1: How do the
geographic distribution of loans and the
distribution of lending by borrower
characteristics interact in the lending
test applicable to either large or small
institutions?
A1. Examiners generally will consider
both the distribution of an institution’s
loans among geographies of different
income levels, and among borrowers of
different income levels and businesses
and farms of different sizes. The
importance of the borrower distribution
criterion, particularly in relation to the
geographic distribution criterion, will
depend on the performance context. For
example, distribution among borrowers
with different income levels may be
more important in areas without
identifiable geographies of different
income categories. On the other hand,
geographic distribution may be more
important in areas with the full range of
geographies of different income
categories.
§ ll.22(b)(2) & (3)–2: Must an
institution lend to all portions of its
assessment area?
A2. The term ‘‘assessment area’’
describes the geographic area within
which the agencies assess how well an
institution, regardless of examination
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type, has met the specific performance
tests and standards in the rule. The
agencies do not expect that simply
because a census tract is within an
institution’s assessment area(s), the
institution must lend to that census
tract. Rather the agencies will be
concerned with conspicuous gaps in
loan distribution that are not explained
by the performance context. Similarly, if
an institution delineated the entire
county in which it is located as its
assessment area, but could have
delineated its assessment area as only a
portion of the county, it will not be
penalized for lending only in that
portion of the county, so long as that
portion does not reflect illegal
discrimination or arbitrarily exclude
low- or moderate-income geographies.
The capacity and constraints of an
institution, its business decisions about
how it can best help to meet the needs
of its assessment area(s), including those
of low- and moderate-income
neighborhoods, and other aspects of the
performance context, are all relevant to
explain why the institution is serving or
not serving portions of its assessment
area(s).
§ ll.22(b)(2) & (3)–3: Will examiners
take into account loans made by
affiliates when evaluating the
proportion of an institution’s lending in
its assessment area(s)?
A3. Examiners will not take into
account loans made by affiliates when
determining the proportion of an
institution’s lending in its assessment
area(s), even if the institution elects to
have its affiliate lending considered in
the remainder of the lending test
evaluation. However, examiners may
consider an institution’s business
strategy of conducting lending through
an affiliate in order to determine
whether a low proportion of lending in
the assessment area(s) should adversely
affect the institution’s lending test
rating.
§ ll.22(b)(2) & (3)–4: When will
examiners consider loans (other than
community development loans) made
outside an institution’s assessment
area(s)?
A4. Consideration will be given for
loans to low- and moderate-income
persons and small business and farm
loans outside of an institution’s
assessment area(s), provided the
institution has adequately addressed the
needs of borrowers within its
assessment area(s). The agencies will
apply this consideration not only to
loans made by large retail institutions
being evaluated under the lending test,
but also to loans made by small and
intermediate small institutions being
evaluated under their respective
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performance standards. Loans to lowand moderate-income persons and small
businesses and farms outside of an
institution’s assessment area(s),
however, will not compensate for poor
lending performance within the
institution’s assessment area(s).
§ ll.22(b)(2) & (3)–5: Under the
lending test applicable to small,
intermediate small, or large institutions,
how will examiners evaluate home
mortgage loans to middle- or upperincome individuals in a low- or
moderate-income geography?
A5. Examiners will consider these
home mortgage loans under the
performance criteria of the lending test,
i.e., by number and amount of home
mortgage loans, whether they are inside
or outside the financial institution’s
assessment area(s), their geographic
distribution, and the income levels of
the borrowers. Examiners will use
information regarding the financial
institution’s performance context to
determine how to evaluate the loans
under these performance criteria.
Depending on the performance context,
examiners could view home mortgage
loans to middle-income individuals in a
low-income geography very differently.
For example, if the loans are for homes
or multifamily housing located in an
area for which the local, state, tribal, or
Federal government or a communitybased development organization has
developed a revitalization or
stabilization plan (such as a Federal
enterprise community or empowerment
zone) that includes attracting mixedincome residents to establish a
stabilized, economically diverse
neighborhood, examiners may give more
consideration to such loans, which may
be viewed as serving the low- or
moderate-income community’s needs as
well as serving those of the middle- or
upper-income borrowers. If, on the other
hand, no such plan exists and there is
no other evidence of governmental
support for a revitalization or
stabilization project in the area and the
loans to middle- or upper-income
borrowers significantly disadvantage or
primarily have the effect of displacing
low- or moderate-income residents,
examiners may view these loans simply
as home mortgage loans to middle- or
upper-income borrowers who happen to
reside in a low- or moderate-income
geography and weigh them accordingly
in their evaluation of the institution.
§ ll.22(b)(4) Community Development
Lending
§ ll.22(b)(4)–1: When evaluating an
institution’s record of community
development lending under the lending
test applicable to large institutions, may
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an examiner distinguish among
community development loans on the
basis of the actual amount of the loan
that advances the community
development purpose?
A1. Yes. When evaluating the
institution’s record of community
development lending under 12 CFR
ll.22(b)(4), it is appropriate to give
greater weight to the amount of the loan
that is targeted to the intended
community development purpose. For
example, consider two $10 million
projects (with a total of 100 units each)
that have as their express primary
purpose affordable housing and are
located in the same community. One of
these projects sets aside 40 percent of its
units for low-income residents and the
other project allocates 65 percent of its
units for low-income residents. An
institution would report both loans as
$10 million community development
loans under the 12 CFR ll.42(b)(2)
aggregate reporting obligation. However,
transaction complexity, innovation and
all other relevant considerations being
equal, an examiner should also take into
account that the 65 percent project
provides more affordable housing for
more people per dollar expended.
Under 12 CFR ll.22(b)(4), the
extent of CRA consideration an
institution receives for its community
development loans should bear a direct
relation to the benefits received by the
community and the innovation or
complexity of the loans required to
accomplish the activity, not simply to
the dollar amount expended on a
particular transaction. By applying all
lending test performance criteria, a
community development loan of a lower
dollar amount could meet the credit
needs of the institution’s community to
a greater extent than a community
development loan with a higher dollar
amount, but with less innovation,
complexity, or impact on the
community.
examiners also may give consideration
to related innovations when they
augment the success and effectiveness
of the institution’s lending under its
community development loan programs
or, more generally, its lending under its
loan programs that address the credit
needs of low- and moderate-income
geographies or individuals. For
example:
• In connection with a community
development loan program, an
institution may establish a technical
assistance program under which the
institution, directly or through third
parties, provides affordable housing
developers and other loan recipients
with financial consulting services. Such
a technical assistance program may, by
itself, constitute a community
development service eligible for
consideration under the service test of
the CRA regulations. In addition, the
technical assistance may be favorably
considered as an innovation that
augments the success and effectiveness
of the related community development
loan program.
• In connection with a small business
lending program in a low- or moderateincome area and consistent with safe
and sound lending practices, an
institution may implement a program
under which, in addition to providing
financing, the institution also contracts
with the small business borrowers. Such
a contracting arrangement would not,
standing alone, qualify for CRA
consideration. However, it may be
favorably considered as an innovation
that augments the loan program’s
success and effectiveness, and improves
the program’s ability to serve
community development purposes by
helping to promote economic
development through support of small
business activities and revitalization or
stabilization of low- or moderate-income
geographies.
§ ll.22(b)(5) Innovative or Flexible
Lending Practices
§ ll.22(b)(5)–1: What is the range of
practices that examiners may consider
in evaluating the innovativeness or
flexibility of an institution’s lending
under the lending test applicable to
large institutions?
A1. In evaluating the innovativeness
or flexibility of an institution’s lending
practices (and the complexity and
innovativeness of its community
development lending), examiners will
not be limited to reviewing the overall
variety and specific terms and
conditions of the credit products
themselves. In connection with the
evaluation of an institution’s lending,
§ ll.22(c) Affiliate Lending
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§ ll.22(c)(1) In General
§ ll.22(c)(1)–1: If an institution,
regardless of examination type, elects to
have loans by its affiliate(s) considered,
may it elect to have only certain
categories of loans considered?
A1. Yes. An institution may elect to
have only a particular category of its
affiliate’s lending considered. The basic
categories of loans are home mortgage
loans, small business loans, small farm
loans, community development loans,
and the five categories of consumer
loans (motor vehicle loans, credit card
loans, home equity loans, other secured
loans, and other unsecured loans).
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519
§ ll.22(c)(2) Constraints on Affiliate
Lending
§ ll.22(c)(2)(i) No Affiliate May Claim
a Loan Origination or Loan Purchase if
Another Institution Claims the Same
Loan Origination or Purchase
§ ll.22(c)(2)(i)–1: Regardless of
examination type, how is this constraint
on affiliate lending applied?
A1. This constraint prohibits one
affiliate from claiming a loan origination
or purchase claimed by another affiliate.
However, an institution can count as a
purchase a loan originated by an
affiliate that the institution
subsequently purchases, or count as an
origination a loan later sold to an
affiliate, provided the same loans are
not sold several times to inflate their
value for CRA purposes. For example,
assume that two institutions are
affiliated. Bank A originates a loan and
claims it as a loan origination. Bank B
later purchases the loan. Bank B may
count the loan as a purchased loan.
The same institution may not count
both the origination and purchase.
Thus, for example, if an institution
claims loans made by an affiliated
mortgage company as loan originations,
the institution may not also count the
loans as purchased loans if it later
purchases the loans from its affiliate.
See also Q&As § ll.22(c)(2)(ii)–1 and
§ ll.22(c)(2)(ii)–2.
§ ll.22(c)(2)(ii) If an Institution Elects
To Have Its Supervisory Agency
Consider Loans Within a Particular
Lending Category Made by One or More
of the Institution’s Affiliates in a
Particular Assessment Area, the
Institution Shall Elect To Have the
Agency Consider All Loans Within That
Lending Category in That Particular
Assessment Area Made by All of the
Institution’s Affiliates
§ ll.22(c)(2)(ii)–1: Regardless of
examination type, how is this constraint
on affiliate lending applied?
A1. This constraint prohibits ‘‘cherrypicking’’ affiliate loans within any one
category of loans. The constraint
requires an institution that elects to
have a particular category of affiliate
lending in a particular assessment area
considered to include all loans of that
type made by all of its affiliates in that
particular assessment area. For example,
assume that an institution has several
affiliates, including a mortgage company
that makes loans in the institution’s
assessment area. If the institution elects
to include the mortgage company’s
home mortgage loans, it must include
all of its affiliates’ home mortgage loans
made in its assessment area. In addition,
the institution cannot elect to include
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only those low- and moderate-income
home mortgage loans made by its
affiliates and not home mortgage loans
to middle- and upper-income
individuals or areas.
§ ll.22(c)(2)(ii)–2: Regardless of
examination type, how is this constraint
applied if an institution’s affiliates are
also insured depository institutions
subject to the CRA?
A2. Strict application of this
constraint against ‘‘cherry-picking’’ to
loans of an affiliate that is also an
insured depository institution covered
by the CRA would produce the
anomalous result that the other
institution would, without its consent,
not be able to count its own loans.
Because the agencies did not intend to
deprive an institution subject to the
CRA of receiving consideration for its
own lending, the agencies read this
constraint slightly differently in cases
involving a group of affiliated
institutions, some of which are subject
to the CRA and share the same
assessment area(s). In those
circumstances, an institution that elects
to include all of its mortgage affiliate’s
home mortgage loans in its assessment
area would not automatically be
required to include all home mortgage
loans in its assessment area of another
affiliate institution subject to the CRA.
However, all loans of a particular type
made by any affiliate in the institution’s
assessment area(s) must either be
counted by the lending institution or by
another affiliate institution that is
subject to the CRA. This reading reflects
the fact that a holding company may, for
business reasons, choose to transact
different aspects of its business in
different subsidiary institutions.
However, the method by which loans
are allocated among the institutions for
CRA purposes must reflect actual
business decisions about the allocation
of banking activities among the
institutions and should not be designed
solely to enhance their CRA evaluations.
§ ll.22(d) Lending by a Consortium or
a Third Party
§ ll.22(d)–1: Will equity and equitytype investments in a third party receive
consideration under the lending test?
A1. If an institution has made an
equity or equity-type investment in a
third party, community development
loans made by the third party may be
considered under the lending test. On
the other hand, asset-backed and debt
securities that do not represent an
equity-type interest in a third party will
not be considered under the lending test
unless the securities are booked by the
purchasing institution as a loan. For
example, if an institution purchases
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stock in a community development
corporation (‘‘CDC’’) that primarily
lends in low- and moderate-income
areas or to low- and moderate-income
individuals in order to promote
community development, the institution
may claim a pro rata share of the CDC’s
loans as community development loans.
The institution’s pro rata share is based
on its percentage of equity ownership in
the CDC. Q&A § ll.23(b)–1 provides
information concerning consideration of
an equity or equity-type investment
under the investment test and both the
lending and investment tests. (Note that
in connection with an intermediate
small institution’s CRA performance
evaluation, community development
loans, including pro-rata shares of
community development loans, are
considered only in the community
development test.)
§ ll.22(d)–2: Regardless of
examination type, 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 the community
development criterion. However, loans
originated directly on the books of an
institution or purchased by the
institution are considered to have been
made or purchased directly by the
institution, even if the institution
originated or purchased the loans as a
result of its participation in a loan
consortium. These loans would be
considered under the lending test or
community development test criteria
appropriate to them depending on the
type of loan and type of examination.
§ ll.22(d)–3: 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 institution requests its
supervisory agency to consider its pro
rata share of community development
loans made by the third party, as
allowed under 12 CFR ll.22(d), may
the third party also receive
consideration for these loans?
A3. Yes, regardless of examination
type, as long as the financial institution
and the third party are not affiliates. The
regulations state, at 12 CFR
ll.22(c)(2)(i), that two affiliates may
not both claim the same loan origination
or loan purchase. However, if the
financial institution and the third party
are not affiliates, the third party may
receive consideration for the community
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development loans it originates, and the
financial institution that invested in the
third party may also receive
consideration for its pro rata share of the
same community development loans
under 12 CFR ll.22(d).
§ ll.23—Investment Test
§ ll.23(a) Scope of Test
§ ll.23(a)–1: 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
receive consideration under the CRA
regulations because the regulations do
not distinguish between ‘‘direct’’ and
‘‘indirect’’ investments. Thus, an
institution’s investment in an equity
fund that, in turn, invests in projects
that, for example, provide affordable
housing to low- and moderate-income
individuals, would receive
consideration as a qualified investment
under the CRA regulations, provided the
investment benefits one or more of the
institution’s assessment area(s) or a
broader statewide or regional area(s)
that includes one or more of the
institution’s assessment area(s).
Similarly, an institution may receive
consideration for a direct qualified
investment in a nonprofit organization
that, for example, supports affordable
housing for low- and moderate-income
individuals in the institution’s
assessment area(s) or a broader
statewide or regional area(s) that
includes the institution’s assessment
area(s).
§ ll.23(a)–2: 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 institution’s assessment
area(s)?
A2. There are several ways to
demonstrate that the institution’s
investment in a nationwide fund meets
the geographic requirements, and the
agencies will employ appropriate
flexibility in this regard in reviewing
information the institution provides that
reasonably supports this determination.
As an initial matter, in making this
determination, the agencies would
consider whether the purpose, mandate,
or function of the fund includes serving
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geographies or individuals located
within the institution’s assessment
area(s) or a broader statewide or regional
area that includes the institution’s
assessment area(s). Typically,
information about where a fund’s
investments are expected to be made or
targeted will be found in the fund’s
prospectus, or other documents
provided by the fund prior to or at the
time of the institution’s investment, and
the institution, at its option, may
provide such documentation in
connection with its CRA evaluation. At
the institution’s option, written
documentation provided by fund
managers in connection with the
institution’s investment indicating that
the fund will use its best efforts to
invest in a qualifying activity that meets
the institution’s geographic
requirements also may be used for these
purposes. Similarly, at the institution’s
option, information that a fund has
explicitly earmarked its projects or
investments to its investors and their
specific assessment area(s) or broader
statewide or regional areas that include
the assessment area(s) also may be used
for these purposes. (If any
documentation that has been provided
at the institution’s option as described
above clearly indicates that the fund
‘‘double-counts’’ investments, by
earmarking the same dollars or the same
portions of projects or investments in a
particular geography to more than one
investor, the investment may be
determined not to meet the geographic
requirements of the CRA regulations.) In
addition, at the institution’s option, an
allocation method may be used to
permit the institution to claim a pro-rata
share of each project of the fund.
Nationwide funds are important
sources of investments for low- and
moderate-income and underserved
communities throughout the country
and can be an efficient vehicle for
institutions in making qualified
investments that help meet community
development needs. Prior to investing in
such a fund, an institution should
consider reviewing the fund’s
investment record to see if it is generally
consistent with the institution’s
investment goals and the geographic
considerations in the regulations. See
also Q&As § ll.12(h)–6 and
§ ll12(h)–7 (additional information
about recognition of investments
benefiting an area outside an
institution’s assessment area(s)).
§ ll.23(b) Exclusion
§ ll.23(b)–1: Even though the
regulations state that an activity that is
considered under the lending or service
tests cannot also be considered under
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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 may make it eligible for
consideration under more than one of
the performance tests. For example,
certain investments and related support
provided by a large retail institution to
a CDC may be evaluated under the
lending, investment, and service tests.
Under the service test, the institution
may receive consideration for any
community development services that it
provides to the CDC, such as service by
an executive of the institution on the
CDC’s board of directors. If the
institution makes an investment in the
CDC that the CDC uses to make
community development loans, the
institution may receive consideration
under the lending test for its pro-rata
share of community development loans
made by the CDC. Alternatively, the
institution’s investment may be
considered under the investment test,
assuming it is a qualified investment. In
addition, an institution may elect to
have a part of its investment considered
under the lending test and the
remaining part considered under the
investment test. If the investing
institution opts to have a portion of its
investment evaluated under the lending
test by claiming its pro rata share of the
CDC’s community development loans,
the amount of investment considered
under the investment test will be offset
by that portion. Thus, the institution
would receive consideration under the
investment test for only the amount of
its investment multiplied by the
percentage of the CDC’s assets that meet
the definition of a qualified investment.
§ ll.23(b)–2: 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 test if it subsequently
purchases mortgage-backed securities
that are primarily or exclusively backed
by such loans?
A2. No. Because the institution
received lending test consideration for
the loans that underlie the securities,
the institution may not also receive
consideration under the investment test
for its purchase of the securities. Of
course, an institution may receive
investment test consideration for
purchases of mortgage-backed securities
that are backed by loans to low- and
moderate-income individuals as long as
the securities are not backed primarily
or exclusively by loans that the same
institution originated or purchased.
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§ ll.23(e) Performance Criteria
§ ll.23(e)–1: When applying the
four performance criteria of 12 CFR
ll.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 test than a
qualified investment with a higher
dollar amount that has fewer qualitative
enhancements. The criteria permit an
examiner to qualitatively weight certain
investments differently or to make other
appropriate distinctions when
evaluating an institution’s record of
making qualified investments. For
instance, an examiner should take into
account that a targeted mortgage-backed
security that qualifies as an affordable
housing issue that has only 60 percent
of its face value supported by loans to
low- or moderate-income borrowers
would not provide as much affordable
housing for low- and moderate-income
individuals as a targeted mortgagebacked security with 100 percent of its
face value supported by affordable
housing loans to low- and moderateincome borrowers. The examiner should
describe any differential weighting (or
other adjustment), and its basis in the
Performance Evaluation. See also Q&A
§ ll.12(t)–8 for a discussion about the
qualitative consideration of prior period
investments.
§ ll.23(e)–2: 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 following four performance
criteria:
(1) The dollar amount of qualified
investments;
(2) The innovativeness or complexity
of qualified investments;
(3) The responsiveness of qualified
investments to credit and community
development needs; and
(4) The degree to which the qualified
investments are not routinely provided
by private investors.
With respect to the first criterion,
examiners will determine the dollar
amount of qualified investments by
relying on the figures recorded by the
institution according to generally
accepted accounting principles (GAAP).
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Although institutions may exercise a
range of investment strategies, including
short-term investments, long-term
investments, investments that are
immediately funded, and investments
with a binding, up-front commitment
that are funded over a period of time,
institutions making the same dollar
amount of investments over the same
number of years, all other performance
criteria being equal, would receive the
same level of consideration. Examiners
will include both new and outstanding
investments in this determination. The
dollar amount of qualified investments
also will include the dollar amount of
legally binding commitments recorded
by the institution according to GAAP.
The extent to which qualified
investments receive consideration,
however, depends on how examiners
evaluate the investments under the
remaining three performance criteria—
innovativeness and complexity,
responsiveness, and degree to which the
investment is not routinely provided by
private investors. Examiners also will
consider factors relevant to the
institution’s CRA performance context,
such as the effect of outstanding longterm qualified investments, the pay-in
schedule, and the amount of any cash
call, on the capacity of the institution to
make new investments.
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§ ll.24—Service Test
§ ll.24(d) Performance criteria—Retail
Banking Services
§ ll.24(d)–1: How do examiners
evaluate the availability and
effectiveness of an institution’s systems
for delivering 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 systems,
such as automated teller machines
(‘‘ATMs’’). The principal focus is on an
institution’s current distribution of
branches and its record of opening and
closing branches, particularly branches
located in low- or moderate-income
geographies or primarily serving low- or
moderate-income individuals. However,
an institution is not required to expand
its branch network or operate
unprofitable branches. Under the
service test, alternative systems for
delivering retail banking services, such
as ATMs, are considered only to the
extent that they are effective alternatives
in providing needed services to lowand moderate-income areas and
individuals.
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§ ll.24(d)–2: How do examiners
evaluate an institution’s activities in
connection with Individual
Development Accounts (IDAs)?
A2. Although there is no standard
IDA program, IDAs typically are deposit
accounts targeted to low- and moderateincome families that are designed to
help them accumulate savings for
education or job-training, downpayment and closing costs on a new
home, or start-up capital for a small
business. Once participants have
successfully funded an IDA, their
personal IDA savings are matched by a
public or private entity. Financial
institution participation in IDA
programs comes in a variety of forms,
including providing retail banking
services to IDA account holders,
providing matching dollars or operating
funds to an IDA program, designing or
implementing IDA programs, providing
consumer financial education to IDA
account holders or prospective account
holders, or other means. The extent of
financial institutions’ involvement in
IDAs and the products and services they
offer in connection with the accounts
will vary. Thus, subject to 12 CFR
ll.23(b), examiners evaluate the
actual services and products provided
by an institution in connection with
IDA programs as one or more of the
following: Community development
services, retail banking services,
qualified investments, home mortgage
loans, small business loans, consumer
loans, or community development
loans. See, e.g., Q&A § ll.12(i)–3.
Note that all types of institutions may
participate in IDA programs. Their IDA
activities are evaluated under the
performance criteria of the type of
examination applicable to the particular
institution.
§ ll.24(d)(3) Availability and
Effectiveness of Alternative Systems for
Delivering Retail Banking Services
§ ll.24(d)(3)–1: How will examiners
evaluate alternative systems for
delivering retail banking services?
A1. The regulation recognizes the
multitude of ways in which an
institution can provide services, for
example, ATMs, banking by telephone
or computer, and bank-by-mail
programs. Delivery systems other than
branches will be considered under the
regulation to the extent that they are
effective alternatives to branches in
providing needed services to low- and
moderate-income areas and individuals.
The list of systems in the regulation is
not intended to be comprehensive.
§ ll.24(d)(3)–2: Are debit cards
considered under the service test as an
alternative delivery system?
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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 community, the overall delivery
system that includes the debit card
feature would be considered an
alternative delivery system.
§ ll.24(e) Performance Criteria–
Community Development Services
§ ll.24(e)–1: Under what conditions
may an institution receive consideration
for community development services
offered by affiliates or third parties?
A1. At an institution’s option, the
agencies will consider services
performed by an affiliate or by a third
party on the institution’s behalf under
the service test if the services provided
enable the institution to help meet the
credit needs of its community. Indirect
services that enhance an institution’s
ability to deliver credit products or
deposit services within its community
and that can be quantified may be
considered under the service test, if
those services have not been considered
already under the lending or investment
test (see Q&A § ll.23(b)–1). For
example, an institution that contracts
with a community organization to
provide home ownership counseling to
low- and moderate-income home buyers
as part of the institution’s mortgage
program may receive consideration for
that indirect service under the service
test. In contrast, donations to a
community organization that offers
financial services to low- or moderateincome individuals may be considered
under the investment test, but would
not also be eligible for consideration
under the service test. Services
performed by an affiliate will be treated
the same as affiliate loans and
investments made in the institution’s
assessment area and may be considered
if the service is not claimed by any other
institution. See 12 CFR ll.22(c) and
ll.23(c).
§ ll.25 Community Development Test
for Wholesale or Limited Purpose
Institutions
§ ll.25(a) Scope of Test
§ ll.25(a)–1: How can certain credit
card banks help to meet the credit needs
of their communities without losing
their exemption from the definition of
‘‘bank’’ in the Bank Holding Company
Act (the BHCA), as amended by the
Competitive Equality Banking Act of
1987 (CEBA)?
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A1. Although the BHCA restricts
institutions known as CEBA credit card
banks to credit card operations, a CEBA
credit card bank can engage in
community development activities
without losing its exemption under the
BHCA. A CEBA credit card bank could
provide community development
services and investments without
engaging in operations other than credit
card operations. For example, the bank
could provide credit card counseling, or
the financial expertise of its executives,
free of charge, to community
development organizations. In addition,
a CEBA credit card bank could make
qualified investments, as long as the
investments meet the guidelines for
passive and noncontrolling investments
provided in the BHC Act and the
Board’s Regulation Y. Finally, although
a CEBA credit card bank cannot make
any loans other than credit card loans,
under 12 CFR ll.25(d)(2) (community
development test—indirect activities),
the bank could elect to have part of its
qualified passive and noncontrolling
investments in a third-party lending
consortium considered as community
development lending, provided that the
consortium’s loans otherwise meet the
requirements for community
development lending. When assessing a
CEBA credit card bank’s CRA
performance under the community
development test, examiners will take
into account the bank’s performance
context. In particular, examiners will
consider the legal constraints imposed
by the BHCA on the bank’s activities, as
part of the bank’s performance context
in 12 CFR ll.21(b)(4).
§ ll.25(d) Indirect Activities
§ ll.25(d)–1: How are investments
in third party community development
organizations considered under the
community development test?
A1. Similar to the lending test for
retail institutions, investments in third
party community development
organizations may be considered as
qualified investments or as community
development loans or both (provided
there is no double counting), at the
institution’s option, as described above
in the discussion regarding 12 CFR
ll.22(d) and ll.23(b).
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§ ll.25(e) Benefit to Assessment
Area(s)
§ ll.25(e)–1: How do examiners
evaluate a wholesale or limited purpose
institution’s qualified investment in a
fund that invests in projects nationwide
and which has a primary purpose of
community development, as that is
defined in the regulations?
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A1. If examiners find that a wholesale
or limited purpose institution has
adequately addressed the needs of its
assessment area(s), they will give
consideration to qualified investments,
as well as community development
loans and community development
services, by that institution nationwide.
In determining whether an institution
has adequately addressed the needs of
its assessment area(s), examiners will
consider qualified investments that
benefit a broader statewide or regional
area that includes the institution’s
assessment area(s).
§ ll.25(f) Community Development
Performance Rating
§ ll.25(f)–1: Must a wholesale or
limited purpose institution engage in all
three categories of community
development activities (lending,
investment, and service) to perform well
under the community development test?
A1. No, a wholesale or limited
purpose institution may perform well
under the community development test
by engaging in one or more of these
activities.
§ ll.26—Small Institution
Performance Standards
§ ll.26–1: When evaluating a small
or intermediate small institution’s
performance, will examiners consider,
at the institution’s request, retail and
community development loans
originated or purchased by affiliates,
qualified investments made by affiliates,
or community development services
provided by affiliates?
A1. Yes. However, a small institution
that elects to have examiners consider
affiliate activities must maintain
sufficient information that the
examiners may evaluate these activities
under the appropriate performance
criteria and ensure that the activities are
not claimed by another institution. The
constraints applicable to affiliate
activities claimed by large institutions
also apply to small and intermediate
small institutions. See Q&As addressing
12 CFR ll.22(c)(2) and related
guidance provided to large institutions
regarding affiliate activities. Examiners
will not include affiliate lending in
calculating the percentage of loans and,
as appropriate, other lending-related
activities located in an institution’s
assessment area.
§ ll.26(a) Performance Criteria
§ll.26(a)(2) Intermediate Small
Institutions
§ ll.26(a)(2)–1: When is an
institution examined as an intermediate
small institution?
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A1. When a small institution has met
the intermediate small institution asset
threshold delineated in 12 CFR
ll.12(u)(1) for two consecutive
calendar year-ends, the institution may
be examined under the intermediate
small institution examination
procedures. The regulation does not
specify an additional lag period between
becoming an intermediate small
institution and being examined as an
intermediate small institution, as it does
for large institutions, because an
intermediate small institution is not
subject to CRA data collection and
reporting requirements. Institutions
should contact their primary regulator
for information on examination
schedules.
§ ll.26(b) Lending Test
§ ll.26(b)–1: May examiners
consider, under one or more of the
performance criteria of the small
institution performance standards,
lending-related activities, such as
community development loans and
lending-related qualified investments,
when evaluating a small institution?
A1. Yes. Examiners can consider
‘‘lending-related activities,’’ including
community development loans and
lending-related qualified investments,
when evaluating the first four
performance criteria of the small
institution performance test. Although
lending-related activities are specifically
mentioned in the regulation in
connection with only the first three
criteria (i.e., loan-to-deposit ratio,
percentage of loans in the institution’s
assessment area, and lending to
borrowers of different incomes and
businesses of different sizes), examiners
can also consider these activities when
they evaluate the fourth criteria—
geographic distribution of the
institution’s loans.
Although lending-related community
development activities are evaluated
under the community development test
applicable to intermediate small
institutions, these activities may also
augment the loan-to-deposit ratio
analysis (12 CFR ll.26(b)(1)) and the
percentage of loans in the intermediate
small institution’s assessment area
analysis (12 CFR ll.26(b)(2)), if
appropriate.
§ ll.26(b)–2: What is meant by ‘‘as
appropriate’’ when referring to the fact
that lending-related activities will be
considered, ‘‘as appropriate,’’ under the
various small institution performance
criteria?
A2. ‘‘As appropriate’’ means that
lending-related activities will be
considered when it is necessary to
determine whether an institution meets
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or exceeds the standards for a
satisfactory rating. Examiners will also
consider other lending-related activities
at an institution’s request, provided they
have not also been considered under the
community development test applicable
to intermediate small institutions.
§ ll.26(b)–3: When evaluating a
small institution’s lending performance,
will examiners consider, at the
institution’s request, community
development loans originated or
purchased by a consortium in which the
institution participates or by a third
party in which the institution has
invested?
A3. Yes. However, a small institution
that elects to have examiners consider
community development loans
originated or purchased by a consortium
or third party must maintain sufficient
information on its share of the
community development loans so that
the examiners may evaluate these loans
under the small institution performance
criteria.
§ ll.26(b)–4: Under the small
institution lending test performance
standards, will examiners consider both
loan originations and purchases?
A4. Yes, consistent with the other
assessment methods in the regulation,
examiners will consider both loans
originated and purchased by the
institution. Likewise, examiners may
consider any other loan data the small
institution chooses to provide,
including data on loans outstanding,
commitments, and letters of credit.
§ ll.26(b)–5: Under the small
institution lending test performance
standards, how will qualified
investments be considered for purposes
of determining whether a small
institution receives a satisfactory CRA
rating?
A5. The small institution lending test
performance standards focus on lending
and other lending-related activities.
Therefore, examiners will consider only
lending-related qualified investments
for the purpose of determining whether
a small institution that is not an
intermediate small institution receives a
satisfactory CRA rating.
§ ll.26(b)(1) Loan-to-Deposit Ratio
§ ll.26(b)(1)–1: How is the loan-todeposit ratio calculated?
A1. A small institution’s loan-todeposit ratio is calculated in the same
manner that the Uniform Bank
Performance Report/Uniform Thrift
Performance Report (UBPR/UTPR)
determines the ratio. It is calculated by
dividing the institution’s net loans and
leases by its total deposits. The ratio is
found in the Liquidity and Investment
Portfolio section of the UBPR and
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UTPR. Examiners will use this ratio to
calculate an average since the last
examination by adding the quarterly
loan-to-deposit ratios and dividing the
total by the number of quarters.
§ ll.26(b)(1)–2: How is the
‘‘reasonableness’’ of a loan-to-deposit
ratio evaluated?
A2. No specific ratio is reasonable in
every circumstance, and each small
institution’s ratio is evaluated in light of
information from the performance
context, including the institution’s
capacity to lend, demographic and
economic factors present in the
assessment area, and the lending
opportunities available in the
assessment area(s). If a small
institution’s loan-to-deposit ratio
appears unreasonable after considering
this information, lending performance
may still be satisfactory under this
criterion taking into consideration the
number and the dollar volume of loans
sold to the secondary market or the
number and amount and innovativeness
or complexity of community
development loans and lending-related
qualified investments.
§ ll.26(b)(1)–3: If an institution
makes a large number of loans off-shore,
will examiners segregate the domestic
loan-to-deposit ratio from the foreign
loan-to-deposit ratio?
A3. No. Examiners will look at the
institution’s net loan-to-deposit ratio for
the whole institution, without any
adjustments.
§ ll.26(b)(2) Percentage of Lending
Within Assessment Area(s)
§ ll.26(b)(2)–1: Must a small
institution have a majority of its lending
in its assessment area(s) to receive a
satisfactory performance rating?
A1. No. The percentage of loans and,
as appropriate, other lending-related
activities located in the institution’s
assessment area(s) is but one of the
performance criteria upon which small
institutions are evaluated. If the
percentage of loans and other lending
related activities in an institution’s
assessment area(s) is less than a
majority, then the institution does not
meet the standards for satisfactory
performance only under this criterion.
The effect on the overall performance
rating of the institution, however, is
considered in light of the performance
context, including information
regarding economic conditions; loan
demand; the institution’s size, financial
condition, business strategies, and
branching network; and other aspects of
the institution’s lending record.
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§ ll.26(b)(3) & (4) Distribution of
Lending Within Assessment Area(s) by
Borrower Income and Geographic
Location
§ ll.26(b)(3) & (4)–1: How will a
small institution’s performance be
assessed under these lending
distribution criteria?
A1. Distribution of loans, like other
small institution performance criteria, is
considered in light of the performance
context. For example, a small institution
is not required to lend evenly
throughout its assessment area(s) or in
any particular geography. However, in
order to meet the standards for
satisfactory performance under this
criterion, conspicuous gaps in a small
institution’s loan distribution must be
adequately explained by performance
context factors such as lending
opportunities in the institution’s
assessment area(s), the institution’s
product offerings and business strategy,
and institutional capacity and
constraints. In addition, it may be
impracticable to review the geographic
distribution of the lending of an
institution with very few
demographically distinct geographies
within an assessment area. If sufficient
information on the income levels of
individual borrowers or the revenues or
sizes of business borrowers is not
available, examiners may use loan size
as a proxy for estimating borrower
characteristics, where appropriate.
§ ll.26(c) Intermediate Small
Institution Community Development
Test
§ ll.26(c)–1: How will the
community development test be applied
flexibly for intermediate small
institutions?
A1. Generally, intermediate small
institutions engage in a combination of
community development loans,
qualified investments, and community
development services. An institution
may not simply ignore one or more of
these categories of community
development, nor do the regulations
prescribe a required threshold for
community development loans,
qualified investments, and community
development services. Instead, based on
the institution’s assessment of
community development needs in its
assessment area(s), it may engage in
different categories of community
development activities that are
responsive to those needs and
consistent with the institution’s
capacity.
An intermediate small institution has
the flexibility to allocate its resources
among community development loans,
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qualified investments, and community
development services in amounts that it
reasonably determines are most
responsive to community development
needs and opportunities. Appropriate
levels of each of these activities would
depend on the capacity and business
strategy of the institution, community
needs, and number and types of
opportunities for community
development.
§ ll.26(c)(3) Community Development
Services
§ ll.26(c)(3)–1: What will examiners
consider when evaluating the provision
of community development services by
an intermediate small institution?
A1. Examiners will consider not only
the types of services provided to benefit
low- and moderate-income individuals,
such as low-cost checking accounts and
low-cost remittance services, but also
the provision and availability of services
to low- and moderate-income
individuals, including through branches
and other facilities located in low- and
moderate-income areas. Generally, the
presence of branches located in lowand moderate-income geographies will
help to demonstrate the availability of
banking services to low- and moderateincome individuals.
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§ ll.26(c)(4) Responsiveness to
Community Development Needs
§ ll.26(c)(4)–1: When evaluating an
intermediate small institution’s
community development record, what
will examiners consider when reviewing
the responsiveness of community
development lending, qualified
investments, and community
development services to the community
development needs of the area?
A1. When evaluating an intermediate
small institution’s community
development record, examiners will
consider not only quantitative measures
of performance, such as the number and
amount of community development
loans, qualified investments, and
community development services, but
also qualitative aspects of performance.
In particular, examiners will evaluate
the responsiveness of the institution’s
community development activities in
light of the institution’s capacity,
business strategy, the needs of the
community, and the number and types
of opportunities for each type of
community development activity (its
performance context). Examiners also
will consider the results of any
assessment by the institution of
community development needs, and
how the institution’s activities respond
to those needs.
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An evaluation of the degree of
responsiveness considers the following
factors: the volume, mix, and qualitative
aspects of community development
loans, qualified investments, and
community development services.
Consideration of the qualitative aspects
of performance recognizes that
community development activities
sometimes require special expertise or
effort on the part of the institution or
provide a benefit to the community that
would not otherwise be made available.
(However, ‘‘innovativeness’’ and
‘‘complexity,’’ factors examiners
consider when evaluating a large
institution under the lending,
investment, and service tests, are not
criteria in the intermediate small
institutions’ community development
test.) In some cases, a smaller loan may
have more qualitative benefit to a
community than a larger loan. Activities
are considered particularly responsive
to community development needs if
they benefit low- and moderate-income
individuals in low- or moderate-income
geographies, designated disaster areas,
or distressed or underserved
nonmetropolitan middle-income
geographies. Activities are also
considered particularly responsive to
community development needs if they
benefit low- or moderate-income
geographies.
§ ll.26(d) Performance Rating
§ ll.26(d)–1: How can a small
institution that is not an intermediate
small institution achieve an
‘‘outstanding’’ performance rating?
A1. A small institution that is not an
intermediate small institution that
meets each of the standards in the
lending test for a ‘‘satisfactory’’ rating
and exceeds some or all of those
standards may warrant an
‘‘outstanding’’ performance rating. In
assessing performance at the
‘‘outstanding’’ level, the agencies
consider the extent to which the
institution exceeds each of the
performance standards and, at the
institution’s option, its performance in
making qualified investments and
providing services that enhance credit
availability in its assessment area(s). In
some cases, a small institution may
qualify for an ‘‘outstanding’’
performance rating solely on the basis of
its lending activities, but only if its
performance materially exceeds the
standards for a ‘‘satisfactory’’ rating,
particularly with respect to the
penetration of borrowers at all income
levels and the dispersion of loans
throughout the geographies in its
assessment area(s) that display income
variation. An institution with a high
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loan-to-deposit ratio and a high
percentage of loans in its assessment
area(s), but with only a reasonable
penetration of borrowers at all income
levels or a reasonable dispersion of
loans throughout geographies of
differing income levels in its assessment
area(s), generally will not be rated
‘‘outstanding’’ based only on its lending
performance. However, the institution’s
performance in making qualified
investments and its performance in
providing branches and other services
and delivery systems that enhance
credit availability in its assessment
area(s) may augment the institution’s
satisfactory rating to the extent that it
may be rated ‘‘outstanding.’’
§ ll.26(d)–2: Will a small
institution’s qualified investments,
community development loans, and
community development services be
considered if they do not directly benefit
its assessment area(s)?
A2. Yes. These activities are eligible
for consideration if they benefit a
broader statewide or regional area that
includes a small institution’s
assessment area(s), as discussed more
fully in Q&As § ll.12(h)–6 and
§ ll.12(h)–7.
§ ll.27—Strategic Plan
§ ll.27(c) Plans in General
§ ll.27(c)–1: To what extent will the
agencies provide guidance to an
institution during the development of its
strategic plan?
A1. An institution will have an
opportunity to consult with and provide
information to the agencies on a
proposed strategic plan. Through this
process, an institution is provided
guidance on procedures and on the
information necessary to ensure a
complete submission. For example, the
agencies will provide guidance on
whether the level of detail as set out in
the proposed plan would be sufficient to
permit agency evaluation of the plan.
However, the agencies’ guidance during
plan development and, particularly,
prior to the public comment period, will
not include commenting on the merits
of a proposed strategic plan or on the
adequacy of measurable goals.
§ ll.27(c)–2: How will a joint
strategic plan be reviewed if the
affiliates have different primary Federal
supervisors?
A2. The agencies will coordinate
review of and action on the joint plan.
Each agency will evaluate the
measurable goals for those affiliates for
which it is the primary regulator.
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§ ll.27(f) Plan Content
§ ll.27(f)(1) Measurable Goals
§ ll.27(f)(1)–1: How should annual
measurable goals be specified in a
strategic plan?
A1. Annual measurable goals (e.g.,
number of loans, dollar amount,
geographic location of activity, and
benefit to low- and moderate-income
areas or individuals) must be stated
with sufficient specificity to permit the
public and the agencies to quantify what
performance will be expected. However,
institutions are provided flexibility in
specifying goals. For example, an
institution may provide ranges of
lending amounts in different categories
of loans. Measurable goals may also be
linked to funding requirements of
certain public programs or indexed to
other external factors as long as these
mechanisms provide a quantifiable
standard.
§ ll.27(g) Plan Approval
§ ll.27(g)(2) Public Participation
§ ll.27(g)(2)–1: How will the public
receive notice of a proposed strategic
plan?
A1. An institution submitting a
strategic plan for approval by the
agencies is required to solicit public
comment on the plan for a period of
thirty (30) days after publishing notice
of the plan at least once in a newspaper
of general circulation. The notice should
be sufficiently prominent to attract
public attention and should make clear
that public comment is desired. An
institution may, in addition, provide
notice to the public in any other manner
it chooses.
§ ll.28—Assigned Ratings
§ ll.28–1: Are innovative lending
practices, innovative or complex
qualified investments, and innovative
community development services
required for a ‘‘satisfactory’’ or
‘‘outstanding’’ CRA rating?
A1. No. The performance criterion of
‘‘innovativeness’’ applies only under the
lending, investment, and service tests
applicable to large institutions and the
community development test applicable
to wholesale and limited purpose
institutions. Moreover, even under these
tests, the lack of innovative lending
practices, innovative or complex
qualified investments, or innovative
community development services alone
will not result in a ‘‘needs to improve’’
CRA rating. However, under these tests,
the use of innovative lending practices,
innovative or complex qualified
investments, and innovative community
development services may augment the
consideration given to an institution’s
performance under the quantitative
criteria of the regulations, resulting in a
higher level of performance rating. See
also Q&A § ll.26(c)(4)–1 for a
discussion about responsiveness to
community development needs under
the community development test
applicable to intermediate small
institutions.
§ ll.28(a) Ratings in General
§ ll.28(a)–1: How are institutions
with domestic branches in more than
one state assigned a rating?
A1. The evaluation of an institution
that maintains domestic branches in
more than one state (‘‘multistate
institution’’) will include a written
evaluation and rating of its CRA record
of performance as a whole and in each
state in which it has a domestic branch.
The written evaluation will contain a
separate presentation on a multistate
institution’s performance for each
metropolitan statistical area and the
nonmetropolitan area within each state,
if it maintains one or more domestic
branch offices in these areas. This
separate presentation will contain
conclusions, supported by facts and
data, on performance under the
performance tests and standards in the
regulation. The evaluation of a
multistate institution that maintains a
domestic branch in two or more states
in a multistate metropolitan area will
include a written evaluation (containing
the same information described above)
and rating of its CRA record of
performance in the multistate
metropolitan area. In such cases, the
statewide evaluation and rating will be
adjusted to reflect performance in the
portion of the state not within the
multistate metropolitan statistical area.
§ ll.28(a)–2: How are institutions
that operate within only a single state
assigned a rating?
A2. An institution that operates
within only a single state (‘‘single-state
institution’’) will be assigned a rating of
its CRA record based on its performance
within that state. In assigning this
rating, the agencies will separately
present a single-state institution’s
performance for each metropolitan area
in which the institution maintains one
or more domestic branch offices. This
separate presentation will contain
conclusions, supported by facts and
data, on the single-state institution’s
performance under the performance
tests and standards in the regulation.
§ ll.28(a)–3: How do the agencies
weight performance under the lending,
investment, and service tests for large
retail institutions?
A3. A rating of ‘‘outstanding,’’ ‘‘high
satisfactory,’’ ‘‘low satisfactory,’’ ‘‘needs
to improve,’’ or ‘‘substantial
noncompliance,’’ based on a judgment
supported by facts and data, will be
assigned under each performance test.
Points will then be assigned to each
rating as described in the first matrix set
forth below. A large retail institution’s
overall rating under the lending,
investment, and service tests will then
be calculated in accordance with the
second matrix set forth below, which
incorporates the rating principles in the
regulation.
POINTS ASSIGNED FOR PERFORMANCE UNDER LENDING, INVESTMENT, AND SERVICE TESTS
Lending
Outstanding ..............................................................................................................................................
High Satisfactory ......................................................................................................................................
Low Satisfactory ......................................................................................................................................
Needs To Improve ...................................................................................................................................
Substantial Noncompliance .....................................................................................................................
Service
12
9
6
3
0
Investment
6
4
3
1
0
6
4
3
1
0
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COMPOSITE RATING POINT REQUIREMENTS
[Add points from three tests]
Rating
Total points
Outstanding .......................................................................................................................................................................................
Satisfactory .......................................................................................................................................................................................
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11 through 19.
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527
COMPOSITE RATING POINT REQUIREMENTS—Continued
[Add points from three tests]
Rating
Total points
Needs to Improve .............................................................................................................................................................................
Substantial Noncompliance ..............................................................................................................................................................
Note: There is one exception to the
Composite Rating matrix. An institution may
not receive a rating of ‘‘satisfactory’’ unless
it receives at least ‘‘low satisfactory’’ on the
lending test. Therefore, the total points are
capped at three times the lending test score.
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§ ll.28(b) Lending, Investment, and
Service Test Ratings
§ ll.28(b)–1: How is performance
under the quantitative and qualitative
performance criteria weighed when
examiners assign a CRA rating?
A1. The lending, investment, and
service tests each contain a number of
performance criteria designed to
measure whether an institution is
effectively helping to meet the credit
needs of its entire community,
including low- and moderate-income
neighborhoods, in a safe and sound
manner. Some of these performance
criteria are quantitative, such as number
and amount, and others, such as the use
of innovative or flexible lending
practices, the innovativeness or
complexity of qualified investments,
and the innovativeness and
responsiveness of community
development services, are qualitative.
The performance criteria that deal with
these qualitative aspects of performance
recognize that these loans, qualified
investments, and community
development services sometimes require
special expertise and effort on the part
of the institution and provide a benefit
to the community that would not
otherwise be possible. As such, the
agencies consider the qualitative aspects
of an institution’s activities when
measuring the benefits received by a
community. An institution’s
performance under these qualitative
criteria may augment the consideration
given to an institution’s performance
under the quantitative criteria of the
regulations, resulting in a higher level of
performance and rating.
§ ll.28(c) Effect of Evidence of
Discriminatory or Other Illegal Credit
Practices
§ ll.28(c)–1: What is meant by
‘‘discriminatory or other illegal credit
practices’’?
A1. An institution engages in
discriminatory credit practices if it
discourages or discriminates against
credit applicants or borrowers on a
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prohibited basis, in violation, for
example, of the Fair Housing Act or the
Equal Credit Opportunity Act (as
implemented by Regulation B).
Examples of other illegal credit
practices inconsistent with helping to
meet community credit needs include
violations of:
• The Truth in Lending Act regarding
rescission of certain mortgage
transactions and regarding disclosures
and certain loan term restrictions in
connection with credit transactions that
are subject to the Home Ownership and
Equity Protection Act;
• The Real Estate Settlement
Procedures Act regarding the giving and
accepting of referral fees, unearned fees
or kickbacks in connection with certain
mortgage transactions; and
• The Federal Trade Commission Act
regarding unfair or deceptive acts or
practices. Examiners will determine the
effect of evidence of illegal credit
practices as set forth in examination
procedures and § ll.28(c) of the
regulation.
Violations of other provisions of the
consumer protection laws generally will
not adversely affect an institution’s CRA
rating, but may warrant the inclusion of
comments in an institution’s
performance evaluation. These
comments may address the institution’s
policies, procedures, training programs,
and internal assessment efforts.
§ ll.29—Effect of CRA Performance
on Applications
§ ll.29(a) CRA Performance
§ ll.29(a)–1: What weight is given to
an institution’s CRA performance
examination in reviewing an
application?
A1. In reviewing applications in
which CRA performance is a relevant
factor, information from a CRA
examination of the institution is a
particularly important consideration.
The examination is a detailed
evaluation of the institution’s CRA
performance by its Federal supervisory
agency. In this light, an examination is
an important, and often controlling,
factor in the consideration of an
institution’s record. In some cases,
however, the examination may not be
recent, or a specific issue raised in the
application process, such as progress in
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0 through 4.
addressing weaknesses noted by
examiners, progress in implementing
commitments previously made to the
reviewing agency, or a supported
allegation from a commenter, is relevant
to CRA performance under the
regulation and was not addressed in the
examination. In these circumstances,
the applicant should present sufficient
information to supplement its record of
performance and to respond to the
substantive issues raised in the
application proceeding.
§ ll.29(a)–2: What consideration is
given to an institution’s commitments
for future action in reviewing an
application by those agencies that
consider such commitments?
A2. Commitments for future action
are not viewed as part of the CRA record
of performance. In general, institutions
cannot use commitments made in the
applications process to overcome a
seriously deficient record of CRA
performance. However, commitments
for improvements in an institution’s
performance may be appropriate to
address specific weaknesses in an
otherwise satisfactory record or to
address CRA performance when a
financially troubled institution is being
acquired.
§ ll.29(b) Interested Parties
§ ll.29(b)–1: What consideration is
given to comments from interested
parties in reviewing an application?
A1. Materials relating to CRA
performance received during the
application process can provide
valuable information. Written
comments, which may express either
support for or opposition to the
application, are made a part of the
record in accordance with the agencies’
procedures, and are carefully
considered in making the agencies’
decisions. Comments should be
supported by facts about the applicant’s
performance and should be as specific
as possible in explaining the basis for
supporting or opposing the application.
These comments must be submitted
within the time limits provided under
the agencies’ procedures.
§ ll.29(b)–2: Is an institution
required to enter into agreements with
private parties?
A2. No. Although communications
between an institution and members of
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its community may provide a valuable
method for the institution to assess how
best to address the credit needs of the
community, the CRA does not require
an institution to enter into agreements
with private parties. The agencies do
not monitor compliance with nor
enforce these agreements.
§ ll.41—Assessment Area Delineation
§ ll.41(a) In General
§ ll.41(a)–1: How do the agencies
evaluate ‘‘assessment areas’’ under the
CRA regulations?
A1. The rule focuses on the
distribution and level of an institution’s
lending, investments, and services
rather than on how and why an
institution delineated its assessment
area(s) in a particular manner.
Therefore, the agencies will not evaluate
an institution’s delineation of its
assessment area(s) as a separate
performance criterion. Rather, the
agencies will only review whether the
assessment area delineated by the
institution complies with the limitations
set forth in the regulations at
§ ll.41(e).
§ ll.41(a)–2: If an institution elects
to have the agencies consider affiliate
lending, will this decision affect the
institution’s assessment area(s)?
A2. If an institution elects to have the
lending activities of its affiliates
considered in the evaluation of the
institution’s lending, the geographies in
which the affiliate lends do not affect
the institution’s delineation of
assessment area(s).
§ ll.41(a)–3: Can a financial
institution identify a specific racial or
ethnic group rather than a geographic
area as its assessment area?
A3. No, assessment areas must be
based on geography. The only exception
to the requirement to delineate an
assessment area based on geography is
that an institution, the business of
which predominantly consists of
serving the needs of military personnel
or their dependents who are not located
within a defined geographic area, may
delineate its entire deposit customer
base as its assessment area.
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§ ll.41(c) Geographic Area(s) for
Institutions Other Than Wholesale or
Limited Purpose Institutions
§ ll.41(c)(1) Generally Consist of One
or More MSAs or Metropolitan
Divisions or One or More Contiguous
Political Subdivisions
§ ll.41(c)(1)–1: Besides cities,
towns, and counties, what other units of
local government are political
subdivisions for CRA purposes?
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A1. Townships and Indian
reservations are political subdivisions
for CRA purposes. Institutions should
be aware that the boundaries of
townships and Indian reservations may
not be consistent with the boundaries of
the census tracts (‘‘geographies’’) in the
area. In these cases, institutions must
ensure that their assessment area(s)
consists only of whole geographies by
adding any portions of the geographies
that lie outside the political subdivision
to the delineated assessment area(s).
§ll.41(c)(1)–2: Are wards, school
districts, voting districts, and water
districts political subdivisions for CRA
purposes?
A2. No. However, an institution that
determines that it predominantly serves
an area that is smaller than a city, town,
or other political subdivision may
delineate as its assessment area the
larger political subdivision and then, in
accordance with 12 CFR ll.41(d),
adjust the boundaries of the assessment
area to include only the portion of the
political subdivision that it reasonably
can be expected to serve. The smaller
area that the institution delineates must
consist of entire geographies, may not
reflect illegal discrimination, and may
not arbitrarily exclude low-or moderateincome geographies.
§ll.41(d) Adjustments to Geographic
Area(s)
§ll.41(d)–1: When may an
institution adjust the boundaries of an
assessment area to include only a
portion of a political subdivision?
A1. Institutions must include whole
geographies (i.e., census tracts) in their
assessment areas and generally should
include entire political subdivisions.
Because census tracts are the common
geographic areas used consistently
nationwide for data collection, the
agencies require that assessment areas
be made up of whole geographies. If
including an entire political subdivision
would create an area that is larger than
the area the institution can reasonably
be expected to serve, an institution may,
but is not required to, adjust the
boundaries of its assessment area to
include only portions of the political
subdivision. For example, this
adjustment is appropriate if the
assessment area would otherwise be
extremely large, of unusual
configuration, or divided by significant
geographic barriers (such as a river,
mountain, or major highway system).
When adjusting the boundaries of their
assessment areas, institutions must not
arbitrarily exclude low- or moderateincome geographies or set boundaries
that reflect illegal discrimination.
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§ll.41(e) Limitations on Delineation
of an Assessment Area
§ll.41(e)(3) May Not Arbitrarily
Exclude Low- or Moderate-Income
Geographies
§ll.41(e)(3)–1: How will examiners
determine whether an institution has
arbitrarily excluded low-or moderateincome geographies?
A1. Examiners will make this
determination on a case-by-case basis
after considering the facts relevant to
the institution’s assessment area
delineation. Information that examiners
will consider may include:
• Income levels in the institution’s
assessment area(s) and surrounding
geographies;
• Locations of branches and deposittaking ATMs;
• Loan distribution in the
institution’s assessment area(s) and
surrounding geographies;
• The institution’s size;
• The institution’s financial
condition; and
• The business strategy, corporate
structure and product offerings of the
institution.
§ll.41(e)(4) May Not Extend
Substantially Beyond an MSA Boundary
or Beyond a State Boundary Unless
Located in a Multistate MSA
§ll.41(e)(4)–1: What are the
maximum limits on the size of an
assessment area?
A1. An institution may not delineate
an assessment area extending
substantially across the boundaries of an
MSA unless the MSA is in a combined
statistical area (CSA)). Although more
than one MSA in a CSA may be
delineated as a single assessment area,
an institution’s CRA performance in
individual MSAs in those assessment
areas will be evaluated using separate
median family incomes and other
relevant information at the MSA level
rather than at the CSA level.
An assessment area also may not
extend substantially across state
boundaries unless the assessment area is
located in a multistate MSA. An
institution may not delineate a whole
state as its assessment area unless the
entire state is contained within an MSA.
These limitations apply to wholesale
and limited purpose institutions as well
as other institutions.
An institution must delineate separate
assessment areas for the areas inside
and outside an MSA if the area served
by the institution’s branches outside the
MSA extends substantially beyond the
MSA boundary. Similarly, the
institution must delineate separate
assessment areas for the areas inside
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and outside of a state if the institution’s
branches extend substantially beyond
the boundary of one state (unless the
assessment area is located in a
multistate MSA). In addition, the
institution should also delineate
separate assessment areas if it has
branches in areas within the same state
that are widely separate and not at all
contiguous. For example, an institution
that has its main office in New York
City and a branch in Buffalo, New York,
and each office serves only the
immediate areas around it, should
delineate two separate assessment areas.
§ll.41(e)(4)–2: May an institution
delineate one assessment area that
consists of an MSA and two large
counties that abut the MSA but are not
adjacent to each other?
A2. As a general rule, an institution’s
assessment area should not extend
substantially beyond the boundary of an
MSA. Therefore, the MSA would be a
separate assessment area, and because
the two abutting counties are not
adjacent to each other and, in this
example, extend substantially beyond
the boundary of the MSA, the
institution would delineate each county
as a separate assessment area, assuming
branches or deposit-taking ATMs are
located in each county and the MSA.
So, in this example, there would be
three assessment areas. However, if the
MSA and the two counties were in the
same CSA, then the institution could
delineate only one assessment area
including them all. But, the institution’s
CRA performance in the MSAs and the
non-MSA counties in that assessment
area would be evaluated using separate
median family incomes and other
relevant information at the MSA and
state, non-MSA level, rather than at the
CSA level.
§ll.42—Data Collection, Reporting,
and Disclosure
§ll.42–1: When must an institution
collect and report data under the CRA
regulations?
A1. All institutions except small
institutions are subject to data collection
and reporting requirements. (‘‘Small
institution’’ is defined in the agencies’
CRA regulations at §ll.12(u).)
Examples describing the data collection
requirements of institutions, in
particular those that have just surpassed
the asset-size threshold of a small
institution, may be found on the FFIEC
Web site at https://www.ffiec.gov/cra. All
institutions that are subject to the data
collection and reporting requirements
must report the data for a calendar year
by March 1 of the subsequent year.
The Board of Governors of the Federal
Reserve System processes the reports for
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all of the primary regulators. Data may
be submitted on diskette, CD–ROM, or
via Internet e-mail. CRA respondents are
encouraged to send their data via the
Internet. E-mail a properly encrypted
CRA file (using the FFIEC software only
Internet e-mail export feature) to the
following e-mail address:
crasub@frb.gov. Please mail diskette or
CD–ROM submissions to: Board of
Governors of the Federal Reserve
System, Attention: CRA Processing,
20th & Constitution Avenue, NW., MS
N502, Washington, DC 20551–0001.
§ll.42–2: Should an institution
develop its own program for data
collection, or will the regulators require
a certain format?
A2. An institution may use the free
software that is provided by the FFIEC
to reporting institutions for data
collection and reporting or develop its
own program. Those institutions that
develop their own programs may create
a data submission using the File
Specifications and Edit Validation Rules
that have been set forth to assist with
electronic data submissions. For
information about specific electronic
formatting procedures, contact the CRA
Assistance Line at (202) 872–7584 or
click on ‘‘How to File’’ at https://
www.ffiec.gov/cra.
§ll.42–3: How should an institution
report data on lines of credit?
A3. Institutions must collect and
report data on lines of credit in the same
way that they provide data on loan
originations. Lines of credit are
considered originated at the time the
line is approved or increased; and an
increase is considered a new
origination. Generally, the full amount
of the credit line is the amount that is
considered originated. In the case of an
increase to an existing line, the amount
of the increase is the amount that is
considered originated and that amount
should be reported. However, consistent
with the Call Report and TFR
instructions, institutions would not
report an increase to a small business or
small farm line of credit if the increase
would cause the total line of credit to
exceed $1 million, in the case of a small
business line, or $500,000, in the case
of a small farm line. Of course,
institutions may provide information
about such line increases to examiners
as ‘‘other loan data.’’
§ll.42–4: Should renewals of lines
of credit be collected and/or reported?
A4. Renewals of lines of credit for
small business, small farm, consumer,
or community development purposes
should be collected and reported, if
applicable, in the same manner as
renewals of small business or small farm
loans. See Q&A §l.42(a)–5. Institutions
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529
that are HMDA reporters continue to
collect and report home equity lines of
credit at their option in accordance with
the requirements of 12 CFR part 203.
§ll.42–5: When should merging
institutions collect data?
A5. Three scenarios of data collection
responsibilities for the calendar year of
a merger and subsequent data reporting
responsibilities are described below.
• Two institutions are exempt from
CRA collection and reporting
requirements because of asset size. The
institutions merge. No data collection is
required for the year in which the
merger takes place, regardless of the
resulting asset size. Data collection
would begin after two consecutive years
in which the combined institution had
year-end assets at least equal to the
small institution asset-size threshold
amount described in 12 CFR
ll.12(u)(1).
• Institution A, an institution
required to collect and report the data,
and Institution B, an exempt institution,
merge. Institution A is the surviving
institution. For the year of the merger,
data collection is required for Institution
A’s transactions. Data collection is
optional for the transactions of the
previously exempt institution. For the
following year, all transactions of the
surviving institution must be collected
and reported.
• Two institutions that each are
required to collect and report the data
merge. Data collection is required for
the entire year of the merger and for
subsequent years so long as the
surviving institution is not exempt. The
surviving institution may file either a
consolidated submission or separate
submissions for the year of the merger
but must file a consolidated report for
subsequent years.
§ll.42–6: Can small institutions get
a copy of the data collection software
even though they are not required to
collect or report data?
A6. Yes. Any institution that is
interested in receiving a copy of the
software may download it from the
FFIEC Web site at https://www.ffiec.gov/
cra. For assistance, institutions may call
the CRA Assistance Line at (202) 872–
7584 or send an e-mail to
CRAHELP@FRB.GOV.
§ll.42–7: If a small institution is
designated a wholesale or limited
purpose institution, must it collect data
that it would not otherwise be required
to collect because it is a small
institution?
A7. No. However, small institutions
that are designated as wholesale or
limited purpose institutions must be
prepared to identify those loans,
investments, and services to be
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evaluated under the community
development test.
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§ll.42(a) Loan Information Required
To Be Collected and Maintained
§ll.42(a)–1: Must institutions
collect and report data on all
commercial loans of $1 million or less
at origination?
A1. No. Institutions that are not
exempt from data collection and
reporting are required to collect and
report only those commercial loans that
they capture in the Call Report,
Schedule RC–C, Part II, and in the TFR,
Schedule SB. Small business loans are
defined as those whose original
amounts are $1 million or less and that
were reported as either ‘‘Loans secured
by nonfarm or nonresidential real
estate’’ or ‘‘Commercial and Industrial
loans’’ in Part I of the Call Report or
TFR.
§ll.42(a)–2: For loans defined as
small business loans, what information
should be collected and maintained?
A2. Institutions that are not exempt
from data collection and reporting are
required to collect and maintain, in a
standardized, machine-readable format,
information on each small business loan
originated or purchased for each
calendar year:
• A unique number or alpha-numeric
symbol that can be used to identify the
relevant loan file;
• The loan amount at origination;
• The loan location; and
• An indicator whether the loan was
to a business with gross annual
revenues of $1 million or less.
The location of the loan must be
maintained by census tract. In addition,
supplemental information contained in
the file specifications includes a date
associated with the origination or
purchase and whether a loan was
originated or purchased by an affiliate.
The same requirements apply to small
farm loans.
§ll.42(a)–3: Will farm loans need to
be segregated from business loans?
A3. Yes.
§ll.42(a)–4: Should institutions
collect and report data on all
agricultural loans of $500,000 or less at
origination?
A4. Institutions are to report those
farm loans that they capture in the Call
Report, Schedule RC–C, Part II and
Schedule SB of the TFR. Small farm
loans are defined as those whose
original amounts are $500,000 or less
and were reported as either ‘‘Loans to
finance agricultural production and
other loans to farmers’’ or ‘‘Loans
secured by farmland’’ in Part I of the
Call Report or TFR.
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§ll.42(a)–5: Should institutions
collect and report data about small
business and small farm loans that are
refinanced or renewed?
A5. An institution should collect
information about small business and
small farm loans that it refinances or
renews as loan originations. (A
refinancing generally occurs when the
existing loan obligation or note is
satisfied and a new note is written,
while a renewal refers to an extension
of the term of a loan. However, for
purposes of small business and small
farm CRA data collection and reporting,
it is not necessary to distinguish
between the two.) When reporting small
business and small farm data, however,
an institution may only report one
origination (including a renewal or
refinancing treated as an origination)
per loan per year, unless an increase in
the loan amount is granted. However, a
demand loan that is merely reviewed
annually is not reported as a renewal
because the term of the loan has not
been extended.
If an institution increases the amount
of a small business or small farm loan
when it extends the term of the loan, it
should always report the amount of the
increase as a small business or small
farm loan origination. The institution
should report only the amount of the
increase if the original or remaining
amount of the loan has already been
reported one time that year. For
example, a financial institution makes a
term loan for $25,000; principal
payments have resulted in a present
outstanding balance of $15,000. In the
next year, the customer requests an
additional $5,000, which is approved,
and a new note is written for $20,000.
In this example, the institution should
report both the $5,000 increase and the
renewal or refinancing of the $15,000 as
originations for that year. These two
originations may be reported together as
a single origination of $20,000.
§ ll.42(a)–6: Does a loan to the
‘‘fishing industry’’ come under the
definition of a small farm loan?
A6. Yes. Instructions for Part I of the
Call Report and Schedule SB of the TFR
include loans ‘‘made for the purpose of
financing fisheries and forestries,
including loans to commercial
fishermen’’ as a component of the
definition for ‘‘Loans to finance
agricultural production and other loans
to farmers.’’ Part II of Schedule RC–C of
the Call Report and Schedule SB of the
TFR, which serve as the basis of the
definition for small business and small
farm loans in the regulation, capture
both ‘‘Loans to finance agricultural
production and other loans to farmers’’
and ‘‘Loans secured by farmland.’’
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§ ll.42(a)–7: How should an
institution report a home equity line of
credit, part of which is for home
improvement purposes and part of
which is for small business purposes?
A7. When an institution originates a
home equity line of credit that is for
both home improvement and small
business purposes, the institution has
the option of reporting the portion of the
home equity line that is for home
improvement purposes as a home
improvement loan under HMDA.
Examiners would consider that portion
of the line when they evaluate the
institution’s home mortgage lending.
When an institution refinances a home
equity line of credit into another home
equity line of credit, HMDA reporting
continues to be optional. If the
institution opts to report the refinanced
line, the entire amount of the line would
be reported as a refinancing and
examiners will consider the entire
refinanced line when they evaluate the
institution’s home mortgage lending.
If an institution that has originated a
home equity line of credit for both home
improvement and small business
purposes (or if an institution that has
refinanced such a line into another line)
chooses not to report a home
improvement loan (or a refinancing)
under HMDA, and if the line meets the
regulatory definition of a ‘‘community
development loan,’’ the institution
should collect and report information
on the entire line as a community
development loan. If the line does not
qualify as a community development
loan, the institution has the option of
collecting and maintaining (but not
reporting) the entire line of credit as
‘‘Other Secured Lines/Loans for
Purposes of Small Business.’’
§ ll.42(a)–8: When collecting small
business and small farm data for CRA
purposes, may an institution collect and
report information about loans to small
businesses and small farms located
outside the United States?
A8. At an institution’s option, it may
collect data about small business and
small farm loans located outside the
United States; however, it cannot report
this data because the CRA data
collection software will not accept data
concerning loan locations outside the
United States.
§ ll.42(a)–9: Is an institution that
has no small farm or small business
loans required to report under CRA?
A9. Each institution subject to data
reporting requirements must, at a
minimum, submit a transmittal sheet,
definition of its assessment area(s), and
a record of its community development
loans. If the institution does not have
community development loans to
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report, the record should be sent with
‘‘0’’ in the community development
loan composite data fields. An
institution that has not purchased or
originated any small business or small
farm loans during the reporting period
would not submit the composite loan
records for small business or small farm
loans.
§ ll.42(a)–10: How should an
institution collect and report the
location of a loan made to a small
business or farm if the borrower
provides an address that consists of a
post office box number or a rural route
and box number?
A10. Prudent banking practices and
Bank Secrecy Act regulations dictate
that institutions know the location of
their customers and loan collateral.
Further, Bank Secrecy Act regulations
specifically state that a post office box
is not an acceptable address. Therefore,
institutions typically will know the
actual location of their borrowers or
loan collateral beyond an address
consisting only of a post office box.
Many borrowers have street addresses
in addition to rural route and box
numbers. Institutions should ask their
borrowers to provide the street address
of the main business facility or farm or
the location where the loan proceeds
otherwise will be applied. Moreover, in
many cases in which the borrower’s
address consists only of a rural route
number, the institution knows the
location (i.e., the census tract) of the
borrower or loan collateral. Once the
institution has this information
available, it should assign the census
tract to that location (geocode) and
report that information as required
under the regulation.
However, if an institution cannot
determine a rural borrower’s street
address, and does not know the census
tract, the institution should report the
borrower’s state, county, MSA or
metropolitan division, if applicable, and
‘‘NA,’’ for ‘‘not available,’’ in lieu of a
census tract code.
§ ll.42(a)(2) Loan Amount at
Origination
§ ll.42(a)(2)–1: When an institution
purchases a small business or small
farm loan, in whole or in part, which
amount should the institution collect
and report—the original amount of the
loan or the amount at purchase?
A1. When collecting and reporting
information on purchased small
business and small farm loans,
including loan participations, an
institution collects and reports the
amount of the loan at origination, not at
the time of purchase. This is consistent
with the Call Report’s and TFR’s use of
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the ‘‘original amount of the loan’’ to
determine whether a loan should be
reported as a ‘‘loan to a small business’’
or a ‘‘loan to a small farm’’ and in which
loan size category a loan should be
reported. When assessing the volume of
small business and small farm loan
purchases for purposes of evaluating
lending test performance under CRA,
however, examiners will evaluate an
institution’s activity based on the
amounts at purchase.
§ ll.42(a)(2)–2: How should an
institution collect data about multiple
loan originations to the same business?
A2. If an institution makes multiple
originations to the same business, the
loans should be collected and reported
as separate originations rather than
combined and reported as they are on
the Call Report or TFR, which reflect
loans outstanding, rather than
originations. However, if institutions
make multiple originations to the same
business solely to inflate artificially the
number or volume of loans evaluated for
CRA lending performance, the agencies
may combine these loans for purposes
of evaluation under the CRA.
§ ll.42(a)(2)–3: How should an
institution collect data pertaining to
credit cards issued to small businesses?
A3. If an institution agrees to issue
credit cards to a business’s employees,
all of the credit card lines opened on a
particular date for that single business
should be reported as one small
business loan origination rather than
reporting each individual credit card
line, assuming the criteria in the ‘‘small
business loan’’ definition in the
regulation are met. The credit card
program’s ‘‘amount at origination’’ is the
sum of all of the employee/business
credit cards’ credit limits opened on a
particular date. If subsequently issued
credit cards increase the small business
credit line, the added amount is
reported as a new origination.
§ ll.42(a)(3) The Loan Location
§ ll.42(a)(3)–1: Which location
should an institution record if a small
business loan’s proceeds are used in a
variety of locations?
A1. The institution should record the
loan location by either the location of
the small business borrower’s
headquarters or the location where the
greatest portion of the proceeds are
applied, as indicated by the borrower.
§ ll.42(a)(4) Indicator of Gross
Annual Revenue
§ ll.42(a)(4)–1: When indicating
whether a small business borrower had
gross annual revenues of $1 million or
less, upon what revenues should an
institution rely?
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531
A1. Generally, an institution should
rely on the revenues that it considered
in making its credit decision. For
example, in the case of affiliated
businesses, such as a parent corporation
and its subsidiary, if the institution
considered the revenues of the entity’s
parent or a subsidiary corporation of the
parent as well, then the institution
would aggregate the revenues of both
corporations to determine whether the
revenues are $1 million or less.
Alternatively, if the institution
considered the revenues of only the
entity to which the loan is actually
extended, the institution should rely
solely upon whether gross annual
revenues are above or below $1 million
for that entity. However, if the
institution considered and relied on
revenues or income of a cosigner or
guarantor that is not an affiliate of the
borrower, such as a sole proprietor, the
institution should not adjust the
borrower’s revenues for reporting
purposes.
§ ll.42(a)(4)–2: If an institution that
is not exempt from data collection and
reporting does not request or consider
revenue information to make the credit
decision regarding a small business or
small farm loan, must the institution
collect revenue information in
connection with that loan?
A2. No. In those instances, the
institution should enter the code
indicating ‘‘revenues not known’’ on the
individual loan portion of the data
collection software or on an internally
developed system. Loans for which the
institution did not collect revenue
information may not be included in the
loans to businesses and farms with gross
annual revenues of $1 million or less
when reporting this data.
§ ll.42(a)(4)–3: What gross revenue
should an institution use in determining
the gross annual revenue of a start-up
business?
A3. The institution should use the
actual gross annual revenue to date
(including $0 if the new business has
had no revenue to date). Although a
start-up business will provide the
institution with pro forma projected
revenue figures, these figures may not
accurately reflect actual gross revenue
and, therefore, should not be used.
§ ll.42(a)(4)–4: When indicating the
gross annual revenue of small business
or small farm borrowers, do institutions
rely on the gross annual revenue or the
adjusted gross annual revenue of their
borrowers?
A4. Institutions rely on the gross
annual revenue, rather than the adjusted
gross annual revenue, of their small
business or small farm borrowers when
indicating the revenue of small business
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or small farm borrowers. The purpose of
this data collection is to enable
examiners and the public to judge
whether the institution is lending to
small businesses and small farms or
whether it is only making small loans to
larger businesses and farms.
The regulation does not require
institutions to request or consider
revenue information when making a
loan; however, if institutions do gather
this information from their borrowers,
the agencies expect them to collect and
rely upon the borrowers’ gross annual
revenue for purposes of CRA. The CRA
regulations similarly do not require
institutions to verify revenue amounts;
thus, institutions may rely on the gross
annual revenue amount provided by
borrowers in the ordinary course of
business. If an institution does not
collect gross annual revenue
information for its small business and
small farm borrowers, the institution
should enter the code ‘‘revenues not
known.’’ (See Q&A § ll.42(a)(4)–2.)
§ll.42(b) Loan Information Required
To Be Reported
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§ll.42(b)(1) Small Business and Small
Farm Loan Data
§ ll.42(b)(1)–1: For small business
and small farm loan information that is
collected and maintained, what data
should be reported?
A1. Each institution that is not
exempt from data collection and
reporting is required to report in
machine-readable form annually by
March 1 the following information,
aggregated for each census tract in
which the institution originated or
purchased at least one small business or
small farm loan during the prior year:
• The number and amount of loans
originated or purchased with original
amounts of $100,000 or less;
• The number and amount of loans
originated or purchased with original
amounts of more than $100,000 but less
than or equal to $250,000;
• The number and amount of loans
originated or purchased with original
amounts of more than $250,000 but not
more than $1 million, as to small
business loans, or $500,000, as to small
farm loans; and
• To the extent that information is
available, the number and amount of
loans to businesses and farms with gross
annual revenues of $1 million or less
(using the revenues the institution
considered in making its credit
decision).
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§ ll.42(b)(2) Community Development
Loan Data
§ ll.42(b)(2)–1: What information
about community development loans
must institutions report?
A1. Institutions subject to data
reporting requirements must report the
aggregate number and amount of
community development loans
originated and purchased during the
prior calendar year.
§ ll.42(b)(2)–2: If a loan meets the
definition of a home mortgage, small
business, or small farm loan AND
qualifies as a community development
loan, where should it be reported? Can
FHA, VA and SBA loans be reported as
community development loans?
A2. Except for multifamily affordable
housing loans, which may be reported
by retail institutions both under HMDA
as home mortgage loans and as
community development loans, in order
to avoid double counting, retail
institutions must report loans that meet
the definition of ‘‘home mortgage loan,’’
‘‘small business loan,’’ or ‘‘small farm
loan’’ only in those respective categories
even if they also meet the definition of
‘‘community development loan.’’ As a
practical matter, this is not a
disadvantage for institutions evaluated
under the lending, investment, and
service tests because any affordable
housing mortgage, small business, small
farm, or consumer loan that would
otherwise meet the definition of
‘‘community development loan’’ will be
considered elsewhere in the lending
test. Any of these types of loans that
occur outside the institution’s
assessment area can receive
consideration under the borrower
characteristic criteria of the lending test.
See Q&A § ll.22(b)(2) & (3)–4.
Limited purpose and wholesale
institutions that meet the size threshold
for reporting purposes also must report
loans that meet the definitions of home
mortgage, small business, or small farm
loans in those respective categories.
However, these institutions must also
report any loans from those categories
that meet the regulatory definition of
‘‘community development loan’’ as
community development loans. There is
no double counting because wholesale
and limited purpose institutions are not
subject to the lending test and,
therefore, are not evaluated on their
level and distribution of home mortgage,
small business, small farm, and
consumer loans.
§ ll.42(b)(2)–3: When the primary
purpose of a loan is to finance an
affordable housing project for low- or
moderate-income individuals, but, for
example, only 40 percent of the units in
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question will actually be occupied by
individuals or families with low or
moderate incomes, should the entire
loan amount be reported as a
community development loan?
A3. Yes. As long as the primary
purpose of the loan is a community
development purpose, the full amount
of the institution’s loan should be
included in its reporting of aggregate
amounts of community development
lending. However, as noted in Q&A
§ ll.22(b)(4)–1, examiners may make
qualitative distinctions among
community development loans on the
basis of the extent to which the loan
advances the community development
purpose.
§ ll.42(b)(2)–4: When an institution
purchases a participation in a
community development loan, which
amount should the institution report—
the entire amount of the credit
originated by the lead lender or the
amount of the participation purchased?
A4. The institution reports only the
amount of the participation purchased
as a community development loan.
However, the institution uses the entire
amount of the credit originated by the
lead lender to determine whether the
original credit meets the definition of a
‘‘loan to a small business,’’ ‘‘loan to a
small farm,’’ or ‘‘community
development loan.’’ For example, if an
institution purchases a $400,000
participation in a business credit that
has a community development purpose,
and the entire amount of the credit
originated by the lead lender is over $1
million, the institution would report
$400,000 as a community development
loan.
§ ll.42(b)(2)–5: Should institutions
collect and report data about
community development loans that are
refinanced or renewed?
A5. Yes. Institutions should collect
information about community
development loans that they refinance
or renew as loan originations.
Community development loan
refinancings and renewals are subject to
the reporting limitations that apply to
refinancings and renewals of small
business and small farm loans. See Q&A
§ ll.42(a)–5.
§ ll.42(b)(3) Home Mortgage Loans
§ ll.42(b)(3)–1: Must institutions
that are not required to collect home
mortgage loan data by the HMDA collect
home mortgage loan data for purposes
of the CRA?
A1. No. If an institution is not
required to collect home mortgage loan
data by the HMDA, the institution need
not collect home mortgage loan data
under the CRA. Examiners will sample
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these loans to evaluate the institution’s
home mortgage lending. If an institution
wants to ensure that examiners consider
all of its home mortgage loans, the
institution may collect and maintain
data on these loans.
§ ll.42(c) Optional Data Collection
and Maintenance
§ ll.42(c)(1) Consumer Loans
§ ll.42(c)(1)–1: What are the data
requirements regarding consumer loans?
A1. There are no data reporting
requirements for consumer loans.
Institutions may, however, opt to collect
and maintain data on consumer loans. If
an institution chooses to collect
information on consumer loans, it may
collect data for one or more of the
following categories of consumer loans:
motor vehicle, credit card, home equity,
other secured, and other unsecured. If
an institution collects data for loans in
a certain category, it must collect data
for all loans originated or purchased
within that category. The institution
must maintain these data separately for
each category for which it chooses to
collect data. The data collected and
maintained should include for each
loan:
• A unique number or alpha-numeric
symbol that can be used to identify the
relevant loan file;
• The loan amount at origination or
purchase;
• The loan location; and
• The gross annual income of the
borrower that the institution considered
in making its credit decision.
Generally, guidance given with
respect to data collection of small
business and small farm loans,
including, for example, guidance
regarding collecting loan location data,
and whether to collect data in
connection with refinanced or renewed
loans, will also apply to consumer
loans.
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§ ll.42(c)(1)(iv) Income of Borrower
§ ll.42(c)(1)(iv)–1: If an institution
does not consider income when making
an underwriting decision in connection
with a consumer loan, must it collect
income information?
A1. No. Further, if the institution
routinely collects, but does not verify, a
borrower’s income when making a
credit decision, it need not verify the
income for purposes of data
maintenance.
§ ll.42(c)(1)(iv)–2: May an
institution list ‘‘0’’ in the income field
on consumer loans made to employees
when collecting data for CRA purposes
as the institution would be permitted to
do under HMDA?
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A2. Yes.
§ ll.42(c)(1)(iv)–3: When collecting
the gross annual income of consumer
borrowers, do institutions collect the
gross annual income or the adjusted
gross annual income of the borrowers?
A3. Institutions collect the gross
annual income, rather than the adjusted
gross annual income, of consumer
borrowers. The purpose of income data
collection in connection with consumer
loans is to enable examiners to
determine the distribution, particularly
in the institution’s assessment area(s), of
the institution’s consumer loans, based
on borrower characteristics, including
the number and amount of consumer
loans to low-, moderate-, middle-, and
upper-income borrowers, as determined
on the basis of gross annual income.
The regulation does not require
institutions to request or consider
income information when making a
loan; however, if institutions do gather
this information from their borrowers,
the agencies expect them to collect the
borrowers’ gross annual income for
purposes of CRA. The CRA regulations
similarly do not require institutions to
verify income amounts; thus,
institutions may rely on the gross
annual income amount provided by
borrowers in the ordinary course of
business.
§ ll.42(c)(1)(iv)–4: Whose income
does an institution collect when a
consumer loan is made to more than
one borrower?
A4. An institution that chooses to
collect and maintain information on
consumer loans collects the gross
annual income of all primary obligors
for consumer loans, to the extent that
the institution considered the income of
the obligors when making the decision
to extend credit. Primary obligors
include co-applicants and co-borrowers,
including co-signers. An institution
does not, however, collect the income of
guarantors on consumer loans, because
guarantors are only secondarily liable
for the debt.
§ ll.42(c)(2) Other Loan Data
§ ll.42(c)(2)–1: Schedule RC–C, Part
II of the Call Report does not allow
banks to report loans for commercial
and industrial purposes that are secured
by residential real estate, unless the
security interest in the nonfarm
residential real estate is taken only as
an abundance of caution. (See Q&A
§ ll.12(v)–3.) Loans extended to small
businesses with gross annual revenues
of $1 million or less may, however, be
secured by residential real estate. May a
bank collect this information to
supplement its small business lending
data at the time of examination?
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A1. Yes. If these loans promote
community development, as defined in
the regulation, the bank should collect
and report information about the loans
as community development loans.
Otherwise, at the bank’s option, it may
collect and maintain data concerning
loans, purchases, and lines of credit
extended to small businesses and
secured by nonfarm residential real
estate for consideration in the CRA
evaluation of its small business lending.
A bank may collect this information as
‘‘Other Secured Lines/Loans for
Purposes of Small Business’’ in the
individual loan data. This information
should be maintained at the bank but
should not be submitted for central
reporting purposes.
§ ll.42(c)(2)–2: Must an institution
collect data on loan commitments and
letters of credit?
A2. No. Institutions are not required
to collect data on loan commitments
and letters of credit. Institutions may,
however, provide for examiner
consideration information on letters of
credit and commitments.
§ ll.42(c)(2)–3: Are commercial and
consumer leases considered loans for
purposes of CRA data collection?
A3. Commercial and consumer leases
are not considered small business or
small farm loans or consumer loans for
purposes of the data collection
requirements in 12 CFRll.42(a) &
(c)(1). However, if an institution wishes
to collect and maintain data about
leases, the institution may provide this
data to examiners as ‘‘other loan data’’
under 12 CFRll.42(c)(2) for
consideration under the lending test.
§ ll.42(d) Data on Affiliate Lending
§ ll.42(d)–1: If an institution elects
to have an affiliate’s home mortgage
lending considered in its CRA
evaluation, what data must the
institution make available to examiners?
A1. If the affiliate is a HMDA reporter,
the institution must identify those loans
reported by its affiliate under 12 CFR
part 203 (Regulation C, implementing
HMDA). At its option, the institution
may provide examiners with either the
affiliate’s entire HMDA Disclosure
Statement or just those portions
covering the loans in its assessment
area(s) that it is electing to consider. If
the affiliate is not required by HMDA to
report home mortgage loans, the
institution must provide sufficient data
concerning the affiliate’s home mortgage
loans for the examiners to apply the
performance tests.
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§ ll.43—Content and Availability of
Public File
§ ll.43(b) Additional Information
Available to the Public
§ ll.43(a) Information Available to the
Public
§ ll.43(b)(1) Institutions Other Than
Small Institutions
§ ll.43(b)(1)–1: Must an institution
that elects to have affiliate lending
considered include data on this lending
in its public file?
A1. Yes. The lending data to be
contained in an institution’s public file
covers the lending of the institution’s
affiliates, as well as of the institution
itself, considered in the assessment of
the institution’s CRA performance. An
institution that has elected to have
mortgage loans of an affiliate considered
must include either the affiliate’s
HMDA Disclosure Statements for the
two prior years or the parts of the
Disclosure Statements that relate to the
institution’s assessment area(s), at the
institution’s option.
§ ll.43(b)(1)–2: May an institution
retain its CRA disclosure statement in
electronic format in its public file, rather
than printing a hard copy of the CRA
disclosure statement for retention in its
public file?
A2. Yes, if the institution can readily
print out its CRA disclosure statement
from an electronic medium (e.g., CD,
DVD, or Internet Web site) when a
consumer requests the public file. If the
request is at a branch other than the
main office or the one designated
branch in each state that holds the
complete public file, the institution
should provide the CRA disclosure
statement in a paper copy, or in another
format acceptable to the requestor,
within 5 calendar days, as required by
12 CFRll.43(c)(2)(ii).
§ ll.43(a)(1) Public Comments Related
to an Institution’s CRA Performance
§ ll.43(a)(1)–1: What happens to
comments received by the agencies?
A1. Comments received by a Federal
financial supervisory agency will be on
file at the agency for use by examiners.
Those comments are also available to
the public unless they are exempt from
disclosure under the Freedom of
Information Act.
§ ll.43(a)(1)–2: Is an institution
required to respond to public
comments?
A2. No. All institutions should review
comments and complaints carefully to
determine whether any response or
other action is warranted. A small
institution subject to the small
institution performance standards is
specifically evaluated on its record of
taking action, if warranted, in response
to written complaints about its
performance in helping to meet the
credit needs in its assessment area(s) (12
CFRll .26(b)(5)). For all institutions,
responding to comments may help to
foster a dialogue with members of the
community or to present relevant
information to an institution’s Federal
financial supervisory agency. If an
institution responds in writing to a
letter in the public file, the response
must also be placed in that file, unless
the response reflects adversely on any
person or placing it in the public file
violates a law.
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§ ll.43(a)(2) CRA Performance
Evaluation
§ ll.43(a)(2)–1: May an institution
include a response to its CRA
performance evaluation in its public
file?
A1. Yes. However, the format and
content of the evaluation, as transmitted
by the supervisory agency, may not be
altered or abridged in any manner. In
addition, an institution that received a
less than satisfactory rating during it
most recent examination must include
in its public file a description of its
current efforts to improve its
performance in helping to meet the
credit needs of its entire community.
See 12 CFRll .43(b)(5). The
institution must update the description
on a quarterly basis.
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§ ll.43(c) Location of Public
Information
§ ll.43(c)–1: What is an institution’s
‘‘main office’’?
A1. An institution’s main office is the
main, home, or principal office as
designated in its charter.
§ ll.43(c)–2: May an institution
maintain a copy of its public file on an
intranet or the Internet?
A2. Yes, an institution may keep all
or part of its public file on an intranet
or the Internet, provided that the
institution maintains all of the
information, either in paper or
electronic form, that is required in
§ ll.43 of the regulations. An
institution that opts to keep part or all
of its public file on an intranet or the
Internet must follow the rules in 12
CFRll.43(c)(1) and (2) as to what
information is required to be kept at a
main office and at a branch. The
institution also must ensure that the
information required to be maintained
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at a main office and branch, if kept
electronically, can be readily
downloaded and printed for any
member of the public who requests a
hard copy of the information.
§ ll .44—Public Notice by Institutions
§ ll.44–1: Are there any placement
or size requirements for an institution’s
public notice?
A1. The notice must be placed in the
institution’s public lobby, but the size
and placement may vary. The notice
should be placed in a location and be of
a sufficient size that customers can
easily see and read it.
§ ll.45—Publication of Planned
Examination Schedule
§ ll.45–1: Where will the agencies
publish the planned examination
schedule for the upcoming calendar
quarter?
A1. The agencies may use the Federal
Register, a press release, the Internet, or
other existing agency publications for
disseminating the list of the institutions
scheduled for CRA examinations during
the upcoming calendar quarter.
Interested parties should contact the
appropriate Federal financial
supervisory agency for information on
how the agency is publishing the
planned examination schedule.
§ ll.45–2: Is inclusion on the list of
institutions that are scheduled to
undergo CRA examinations in the next
calendar quarter determinative of
whether an institution will be examined
in that quarter?
A2. No. The agencies attempt to
determine as accurately as possible
which institutions will be examined
during the upcoming calendar quarter.
However, whether an institution’s name
appears on the published list does not
conclusively determine whether the
institution will be examined during that
quarter. The agencies may need to defer
a planned examination or conduct an
unforeseen examination because of
scheduling difficulties or other
circumstances.
Appendix A to Partll—Ratings
Appendix A to Partll–1: Must an
institution’s performance fit each aspect
of a particular rating profile in order to
receive that rating?
A1. No. Exceptionally strong
performance in some aspects of a
particular rating profile may
compensate for weak performance in
others. For example, a retail institution
other than an intermediate small
institution that uses non-branch
delivery systems to obtain deposits and
to deliver loans may have almost all of
its loans outside the institution’s
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assessment area. Assume that an
examiner, after consideration of
performance context and other
applicable regulatory criteria, concludes
that the institution has weak
performance under the lending criteria
applicable to lending activity,
geographic distribution, and borrower
characteristics within the assessment
area. The institution may compensate
for such weak performance by
exceptionally strong performance in
community development lending in its
assessment area or a broader statewide
or regional area that includes its
assessment area.
Appendix B to Partll—CRA Notice
Appendix B to Partll–1: What
agency information should be added to
the CRA notice form?
A1. The following information should
be added to the form:
OCC-supervised institutions only: For
community banks, the address of the
deputy comptroller of the district in
which the institution is located should
be inserted in the appropriate blank.
These addresses can be found at https://
www.occ.gov. For banks supervised
under the large bank program, insert
‘‘Large Bank Supervision, 250 E Street,
SW., Washington, DC 20219–0001.’’ For
banks supervised under the mid-size/
credit card bank program, insert ‘‘MidSize and Credit Card Bank Supervision,
250 E Street, SW., Washington, DC
20219–0001.’’
OCC-, FDIC-, and Board-supervised
institutions: ‘‘Officer in Charge of
Supervision’’ is the title of the
responsible official at the appropriate
Federal Reserve Bank.
INDEX
Keyword
Q&A
Affiliate lending .........................................................................................................................................
Affiliates ....................................................................................................................................................
Affordable housing ...................................................................................................................................
Agreements, private .................................................................................................................................
Alternative delivery systems ....................................................................................................................
Applications, corporate .............................................................................................................................
Assessment areas ....................................................................................................................................
Assessment area, benefit to ....................................................................................................................
Assets .......................................................................................................................................................
ATMs ........................................................................................................................................................
Borrower characteristics ...........................................................................................................................
Branch ......................................................................................................................................................
sroberts on PROD1PC70 with NOTICES
Brokerage .................................................................................................................................................
Capital investments ..................................................................................................................................
CEBA credit card banks ...........................................................................................................................
Charitable contributions or activities ........................................................................................................
Child care services ...................................................................................................................................
Commercial loans ....................................................................................................................................
Commitments ...........................................................................................................................................
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§ ll.22(b)(2) & (3)–3
§ ll.22(c)(1)–1
§ ll.22(c)(2)(i)–1
§ ll.22(c)(2)(ii)–1
§ ll.22(c)(2)(ii)–2
§ ll.26–1
§ ll.41(a)–2
§ ll.42(d)–1
§ ll.43(b)(1)–1
§ ll.12(a)–1
§ ll.22(d)–3
§ ll.12(g)–1
§ ll.12(g)–2
§ ll.12(g)(1)–1
§ ll.29(b)–2
§ ll.24(d)–1
§ ll.24(d)(3)–1
§ ll.24(d)(3)–2
§ ll.29(a)–1
§ ll.29(a)–2
§ ll.29(b)–1
§ ll.22(b)(2) & (3)–2
§ ll.22(b)(2) & (3)–3
§ ll.41(a)–1
§ ll.41(a)–2
§ ll.41(a)–3
§ ll.41(c)(1)–1
§ ll.41(c)(1)–2
§ ll.41(d)–1
§ ll.41(e)(3)–1
§ ll.41(e)(4)–1
§ ll.41(e)(4)–2
§ ll.12(g)–4
§ ll.12(h)–6
§ ll.12(u)–1
§ ll.12(u)(2)–1
§ ll.12(f)–1
§ ll.24(d)–1
§ ll.24(d)(3)–1
§ ll.22(b)(2) & (3)–1
§ ll.12(f)–1
§ ll.12(f)–2
§ ll.28(a)–1
§ ll.12(l)–2
§ ll.12(g)–4
§ ll.25(a)–1
§ ll.12(i)–2
§ ll.12(t)–5
§ ll.12(g)–1
§ ll.12(v)–2
§ ll.42(a)–1
§ ll.22(a)(2)–1
§ ll.22(a)(2)–4
§ ll.29(a)–2
§ ll.42(c)(2)–2
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
INDEX—Continued
Keyword
Q&A
Community contact interviews .................................................................................................................
Community development .........................................................................................................................
Community development activities ..........................................................................................................
Community development loan .................................................................................................................
Community development service .............................................................................................................
Community development test for intermediate small institutions ............................................................
Community development test for wholesale and limited purpose institutions .........................................
Community services .................................................................................................................................
Complexity ................................................................................................................................................
Consortia ..................................................................................................................................................
sroberts on PROD1PC70 with NOTICES
Consumer loan .........................................................................................................................................
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§ ll.21(b)(2)–2
§ ll.12(g)–1
§ ll.12(g)(1)–1
§ ll.12(g)(3)–1
§ ll.12(g)(4)–1
§ ll.12(h)–5
§ ll.12(h)–8
§ ll.12(t)–5
§ ll.12(g)–2
§ ll.12(g)(4)–2
§ ll.21(a)–2
§ ll.12(h)–1
§ ll.12(h)–2
§ ll.12(h)–3
§ ll.12(h)–4
§ ll.12(h)–5
§ ll.12(h)–6
§ ll.12(h)–7
§ ll.12(h)–8
§ ll.12(t)–6
§ ll.12(v)–1
§ ll.22(b)(4)–1
§ ll.22(d)–2
§ ll.23(b)–1
§ ll.26–1
§ ll.26(b)–3
§ ll.26(c)–1
§ ll.26(d)–2
§ ll.42(b)(2)–1
§ ll.42(b)(2)–2
§ ll.42(b)(2)–3
§ ll.42(b)(2)–4
§ ll.42(b)(2)–5
§ ll.42(c)(2)–1
§ ll.12(h)–6
§ ll.12(h)–7
§ ll.12(h)–8
§ ll.12(i)–1
§ ll.12(i)–2
§ ll.12(i)–3
§ ll.12(l)–2
§ ll.12(t)–7
§ ll.12(v)–3
§ ll.23(b)–1
§ ll.24(e)–1
§ ll.26–1
§ ll.26(c)–1
§ ll.26(c)(3)–1
§ ll.26(d)–2
§ ll.26(b)–1
§ ll.26(c)–1
§ ll.26(c)(3)–1
§ ll.26(c)(4)–1
§ ll.28–1
§ ll.25(d)–1
§ ll.25(f)–1
§ ll.12(g)–2
§ ll.12(t)–4
§ ll.21(a)–2
§ ll.22(b)(5)–1
§ ll.23(e)–2
§ ll.28–1
§ ll.22(d)–2
§ ll.26(b)–3
§ ll.12(h)–2
§ ll.12(j)–1
§ ll.12(j)–2
§ ll.12(x)–1
§ ll.22(a)(1)–2
§ ll.42(c)(1)–1
§ ll.42(c)(1)(iv)–1
§ ll.42(c)(1)(iv)–2
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
INDEX—Continued
Keyword
Q&A
CRA disclosure statement .......................................................................................................................
Credit cards ..............................................................................................................................................
Credit union, low-income .........................................................................................................................
Data collection ..........................................................................................................................................
Data reporting ..........................................................................................................................................
Debit cards ...............................................................................................................................................
Designated disaster area .........................................................................................................................
Distressed nonmetropolitan middle-income geography ...........................................................................
Economic development ............................................................................................................................
sroberts on PROD1PC70 with NOTICES
Education, financial literacy .....................................................................................................................
Educational services ................................................................................................................................
Employees’ charitable activities ...............................................................................................................
Employees’ income ..................................................................................................................................
Environmental hazards ............................................................................................................................
Examination schedule ..............................................................................................................................
Federal branch .........................................................................................................................................
Federal Home Loan Bank ........................................................................................................................
Federal Reserve Bank membership reserves .........................................................................................
Financial services, provision of ................................................................................................................
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§ ll.42(c)(1)(iv)–3
§ ll.42(c)(1)(iv)–4
§ ll.43(b)(1)–2
§ ll.12(h)–4
§ ll.12(v)–4
§ ll.42(a)(2)–3
§ ll.12(g)–4
§ ll.12(t)–4
§ ll.42–1
§ ll.42–2
§ ll.42–4
§ ll.42–5
§ ll.42–6
§ ll.42–7
§ ll.42(a)–1
§ ll.42(a)–2
§ ll.42(a)–4
§ ll.42(a)–5
§ ll.42(a)–8
§ ll.42(a)–10
§ ll.42(a)(2)–1
§ ll.42(a)(2)–2
§ ll.42(a)(2)–3
§ ll.42(a)(4)–2
§ ll.42(a)(4)–4
§ ll.42(b)(2)–5
§ ll.42(b)(3)–1
§ ll.42(c)(1)–1
§ ll.42(c)(1)(iv)–1
§ ll.42(c)(1)(iv)–2
§ ll.42(c)(1)(iv)–3
§ ll.42(c)(1)(iv)–4
§ ll.42(c)(2)–1
§ ll.42–1
§ ll.42–3
§ ll.42–4
§ ll.42(a)–1
§ ll.42(a)–4
§ ll.42(a)–5
§ ll.42(a)–8
§ ll.42(a)–9
§ ll.42(a)–10
§ ll.42(a)(2)–1
§ ll.42(b)(1)–1
§ ll.42(b)(2)–1
§ ll.42(b)(2)–2
§ ll.42(b)(2)–3
§ ll.42(b)(2)–4
§ ll.42(b)(2)–5
§ ll.24(d)(3)–2
§ ll.12(g)(4)–2
§ ll.12(g)(4)(ii)–1
§ ll.12(g)(4)(ii)–2
§ ll.12(g)(4)–2
§ ll.12(g)(4)(iii)–1
§ ll.12(g)(4)(iii)–2
§ ll.12(g)(4)(iii)–3
§ ll.12(g)–1
§ ll.12(g)–2
§ ll.12(g)(3)–1
§ ll.12(i)–3
§ ll.22(a)–1
§ ll.12(g)–1
§ ll.12(i)–2
§ ll.42(c)(1)(iv)–2
§ ll.12(h)–1
§ ll.45–1
§ ll.45–2
§ ll.12(u)–1
§ ll.12(t)–3
§ ll.12(t)–3
§ ll.12(i)–1
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
INDEX—Continued
Keyword
Q&A
Fisheries ...................................................................................................................................................
Flexibility ...................................................................................................................................................
Foreclosure prevention program ..............................................................................................................
Forestries .................................................................................................................................................
Geographic distribution ............................................................................................................................
Geography ................................................................................................................................................
Guaranteed loans .....................................................................................................................................
Guarantor .................................................................................................................................................
Health services .........................................................................................................................................
High cost area ..........................................................................................................................................
HMDA reporting .......................................................................................................................................
Home equity line of credit ........................................................................................................................
Home equity loan .....................................................................................................................................
Home mortgage lending ...........................................................................................................................
Home mortgage loan ...............................................................................................................................
Illegal credit practices ..............................................................................................................................
Income ......................................................................................................................................................
Income level .............................................................................................................................................
Indirect investments .................................................................................................................................
Individual development accounts (IDAs) .................................................................................................
Innovativeness .........................................................................................................................................
Institutional capacity and constraints .......................................................................................................
Intermediate small institution ...................................................................................................................
Internet/intranet ........................................................................................................................................
Investment authority .................................................................................................................................
Leases ......................................................................................................................................................
Lending activity ........................................................................................................................................
Lending distribution ..................................................................................................................................
sroberts on PROD1PC70 with NOTICES
Lending within assessment area .............................................................................................................
Letters of credit ........................................................................................................................................
Limited purpose institution .......................................................................................................................
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§ ll.42(a)–6
§ ll.12(g)–3
§ ll.22(b)(5)–1
§ ll.12(g)(4)(i)–1
§ ll.12(i)–3
§ ll.22(a)–1
§ ll.42(a)–6
§ ll.22(b)(2) & (3)–1
§ ll.12(g)(4)(iii)–1
§ ll.41(d)–1
§ ll.41(e)(3)–1
§ ll.22(a)(2)–5
§ ll.42(c)(1)(iv)–4
§ ll.12(g)–1
§ ll.12(g)–3
§ ll.12(j)–2
§ ll.12(l)–2
§ ll.22(a)(1)–1
§ ll.22(a)(2)–7
§ ll.42(a)–7
§ ll.42(b)(3)–1
§ ll.12(j)–2
§ ll.42(a)–7
§ ll.12(j)–1
§ ll.22(a)(1)–1
§ ll.42(d)–1
§ ll.12(h)–2
§ ll.12(h)–3
§ ll.12(j)–2
§ ll.12(l)–1
§ ll.12(l)–2
§ ll.12(x)–1
§ ll.22(b)(2) & (3)–5
§ ll.23(b)–2
§ ll.42(b)(2)–2
§ ll.42(b)(3)–1
§ ll.28(c)–1
§ ll.42(c)(1)(iv)–1
§ ll.42(c)(1)(iv)–2
§ ll.42(c)(1)(iv)–3
§ ll.42(c)(1)(iv)–4
§ ll.12(m)–1
§ ll.23(a)–1
§ ll.12(i)–3
§ ll.24(d)–2
§ ll.21(a)–2
§ ll.22(b)(5)–1
§ ll.23(e)–2
§ ll.28–1
§ ll.21(b)(4)–1
§ ll.12(h)–3
§ ll.12(u)(2)–1
§ ll.26(a)(2)–1
§ ll.43(b)(1)–2
§ ll.43(c)–2
§ ll.12(t)–1
§ ll.22(a)(2)–4
§ ll.42(c)(2)–3
§ ll.22(b)(1)–1
§ ll.22(b)(2) & (3)–1
§ ll.22(b)(2) & (3)–2
§ ll.22(b)(2) & (3)–3
§ ll.26(b)(3) & (4)–1
§ ll.26(b)(2)–1
§ ll.22(a)(2)–1
§ ll.22(a)(2)–4
§ ll.42(c)(2)–2
§ ll.12(n)–1
§ ll.12(n)–2
§ ll.12(n)–3
§ ll.42–7
§ ll.42(b)(2)–2
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
INDEX—Continued
Keyword
Q&A
Lines of credit ...........................................................................................................................................
Loan amount ............................................................................................................................................
Loan application activity ...........................................................................................................................
Loan location ............................................................................................................................................
Loan originations, multiple .......................................................................................................................
Loan participations ...................................................................................................................................
Loan production office (LPO) ...................................................................................................................
Loans, outside-assessment area .............................................................................................................
Loan-to-deposit ratio ................................................................................................................................
Main office ................................................................................................................................................
Measurable goals .....................................................................................................................................
MECAs .....................................................................................................................................................
Merging institutions ..................................................................................................................................
Minority-owned financial institution ..........................................................................................................
Mobile branch ...........................................................................................................................................
Mortgage-backed securities .....................................................................................................................
Multi-purpose loan ....................................................................................................................................
Municipal bonds .......................................................................................................................................
Nationwide fund .......................................................................................................................................
New Markets Tax Credit Community Development Entity ......................................................................
New Markets Venture Capital Company ..................................................................................................
Niche institution ........................................................................................................................................
Nonprofit organization ..............................................................................................................................
Other loan data ........................................................................................................................................
Past performance .....................................................................................................................................
Performance context ................................................................................................................................
Performance criteria .................................................................................................................................
Performance evaluation ...........................................................................................................................
Performance rating ...................................................................................................................................
sroberts on PROD1PC70 with NOTICES
Political subdivision ..................................................................................................................................
Primary purpose .......................................................................................................................................
Public comment ........................................................................................................................................
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§ ll.42–3
§ ll.42–4
§ ll.42(a)–2
§ ll.42(a)(2)–1
§ ll.22(a)(2)–2
§ ll.42(a)–2
§ ll.42(a)–10
§ ll.42(a)(3)–1
§ ll.42(a)(2)–2
§ ll.12(g)–4
§ ll.22(a)(2)–6
§ ll.42(b)(2)–4
§ ll.12(f)–2
§ ll.22(b)(2) & (3)–4
§ ll.26(b)(1)–1
§ ll.26(b)(1)–2
§ ll.26(b)(1)–3
§ ll.43(c)–1
§ ll.27(f)(1)–1
§ ll.22(a)(2)–3
§ ll.22(a)(2)–4
§ ll.42–5
§ ll.12(g)–4
§ ll.12(t)–4
§ ll.12(f)–1
§ ll.12(t)–2
§ ll.23(b)–2
§ ll.12(j)–3
§ ll.12(t)–2
§ ll.23(a)–2
§ ll.25(e)–1
§ ll.12(g)(3)–1
§ ll.12(h)–1
§ ll.12(t)–4
§ ll.12(g)(3)–1
§ ll.12(n)–3
§ ll.12(v)–1
§ ll.22(a)(2)–4
§ ll.42(c)(2)–1
§ ll.21(b)(5)–1
§ ll.21(b)–1
§ ll.21(b)(2)–1
§ ll.21(b)(2)–2
§ ll.21(b)(4)–1
§ ll.21(b)(5)–1
§ ll.21(b)(5)–2
§ ll.22(a)(2)–2
§ ll.23(e)–2
§ ll.26(c)(4)–1
§ ll.21(a)–1
§ ll.23(e)–1
§ ll.23(e)–2
§ ll.28(b)–1
§ ll.43(a)(2)–1
§ ll.26(d)–1
§ ll.28–1
§ ll.28(a)–1
§ ll.28(a)–2
§ ll.28(a)–3
§ ll.28(b)–1
§ ll.28(c)–1
APPENDIX A to Partl–1
§ ll.41(c)(1)–1
§ ll.41(c)(1)–2
§ ll.41(d)–1
§ ll.12(g)–3
§ ll.12(h)–8
§ ll.12(t)–5
§ ll.27(g)(2)–1
§ ll.29(b)–1
§ ll.43(a)(1)–1
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
INDEX—Continued
Keyword
Q&A
Public file ..................................................................................................................................................
Public notice .............................................................................................................................................
Qualified investment .................................................................................................................................
Qualitative factors ....................................................................................................................................
Ratings matrix ..........................................................................................................................................
Refinancings .............................................................................................................................................
Regional area ...........................................................................................................................................
Remote service facility (RSF) ..................................................................................................................
Renewals ..................................................................................................................................................
Responsiveness .......................................................................................................................................
Retail banking services ............................................................................................................................
Revenue ...................................................................................................................................................
sroberts on PROD1PC70 with NOTICES
Revitalize or stabilize ...............................................................................................................................
SBA 504 Certified Development Company program ...............................................................................
SBIC or SBDC .........................................................................................................................................
Similarly situated lenders .........................................................................................................................
Small business loan .................................................................................................................................
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§ ll.43(a)(1)–2
§ ll.43(a)(1)–2
§ ll.43(a)(2)–1
§ ll.43(b)(1)–1
§ ll.43(b)(1)–2
§ ll.43(c)–2
§ ll.27(g)(2)–1
§ ll.44–1
APPENDIX B to Partl–1
§ ll.12(h)–6
§ ll.12(h)–7
§ ll.12(h)–8
§ ll.12(t)–2
§ ll.12(t)–3
§ ll.12(t)–4
§ ll.12(t)–5
§ ll.12(t)–6
§ ll.12(t)–7
§ ll.12(t)–8
§ ll.23(a)–1
§ ll.23(b)–1
§ ll.23(b)–2
§ ll.23(a)–2
§ ll.23(e)–1
§ ll.23(e)–2
§ ll.26–1
§ ll.26(b)–5
§ ll.26(c)–1
§ ll.26(d)–2
§ ll.12(g)(3)–1
§ ll.12(t)–8
§ ll.21(a)–2
§ ll.22(b)(4)–1
§ ll.22(b)(5)–1
§ ll.23(e)–1
§ ll.23(e)–2
§ ll.26(c)(4)–1
§ ll.28(b)–1
§ ll.28(a)–3
§ ll.22(a)(2)–7
§ ll.42(a)–5
§ ll.42(b)(2)–5
§ ll.12(h)–7
§ ll.12(f)–1
§ ll.42–4
§ ll.42(a)–5
§ ll.42(b)(2)–5
§ ll.21(a)–2
§ ll.22(a)–1
§ ll.23(e)–2
§ ll.26(c)(4)–1
§ ll.28–1
§ ll.12(l)–2
§ ll.24(d)–1
§ ll.42(a)(4)–1
§ ll.42(a)(4)–2
§ ll.42(a)(4)–3
§ ll.42(a)(4)–4
§ ll.12(g)–1
§ ll.12(g)–2
§ ll.12(g)(4)–2
§ ll.12(g)(4)(i)–1
§ ll.12(g)(4)(ii)–2
§ ll.12(g)(4)(iii)–3
§ ll.12(g)(4)(iii)–4
§ ll.12(h)–5
§ ll.12(h)–1
§ ll.12(g)(3)–1
§ ll.12(t)–4
§ ll.21(b)(5)–2
§ ll.12(h)–2
§ ll.12(v)–1
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INDEX—Continued
Keyword
Q&A
Small farm loan ........................................................................................................................................
Small institution ........................................................................................................................................
Small institution performance standards ..................................................................................................
Social services .........................................................................................................................................
Software for data collection and reporting ...............................................................................................
Special purpose institution .......................................................................................................................
State branch .............................................................................................................................................
Strategic plan ...........................................................................................................................................
Subsidiary .................................................................................................................................................
Third party investments ............................................................................................................................
Underserved nonmetropolitan middle-income geography .......................................................................
sroberts on PROD1PC70 with NOTICES
Wholesale institution ................................................................................................................................
Women-owned financial institutions .........................................................................................................
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§ ll.12(v)–2
§ ll.12(v)–3
§ ll.12(v)–4
§ ll.12(x)–1
§ ll.22(a)(2)–7
§ ll.42(a)–2
§ ll.42(a)–3
§ ll.42(a)–5
§ ll.42(a)–8
§ ll.42(a)–10
§ ll.42(a)(2)–1
§ ll.42(a)(2)–3
§ ll.42(a)(3)–1
§ ll.42(a)(4)–1
§ ll.42(a)(4)–2
§ ll.42(b)(2)–2
§ ll.42(c)(2)–1
§ ll.12(h)–2
§ ll.12(v)–1
§ ll.12(x)–1
§ ll.42(a)–2
§ ll.42(a)–3
§ ll.42(a)–4
§ ll.42(a)–5
§ ll.42(a)–6
§ ll.42(a)–8
§ ll.42(a)–10
§ ll.42(a)(2)–1
§ ll.42(a)(4)–2
§ ll.42(b)(2)–2
§ ll.12(u)–1
§ ll.12(u)(2)–1
§ ll.26(b)–1
§ ll.42–1
§ ll.42–6
§ ll.42–7
§ ll.26–1
§ ll.26(b)–1
§ ll.26(b)–2
§ ll.26(b)–3
§ ll.26(b)–4
§ ll.26(b)–5
§ ll.26(b)(3) & (4)–1
§ ll.26(d)–1
§ ll.26(d)–2
§ ll.12(g)–1
§ ll.42–2
§ ll.42–6
§§ ll.11(c)(3) & 563e.11(c)(2)–1
§§ ll.11(c)(3) & 563e.11(c)(2)–2
§ ll.12(u)–1
§ ll.27(c)–1
§ ll.27(c)–2
§ ll.27(f)(1)–1
§ ll.27(g)(2)–1
§ ll.12(a)–1
§ ll.22(d)–1
§ ll.22(d)–2
§ ll.22(d)–3
§ ll.25(d)–1
§ ll.26(b)–3
§ ll.12(g)(4)–2
§ ll.12(g)(4)(iii)–1
§ ll.12(g)(4)(iii)–2
§ ll.12(g)(4)(iii)–4
§ ll.12(n)–2
§ ll.12(n)–3
§ ll.12(x)–1
§ ll.42–7
§ ll.42(b)(2)–2
§ ll.12(g)–4
§ ll.12(t)–4
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Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 / Notices
sroberts on PROD1PC70 with NOTICES
End of text of the Interagency Questions
and Answers
VerDate Nov<24>2008
17:18 Jan 05, 2009
Jkt 217001
Dated: December 9, 2008.
John C. Dugan,
Comptroller of the Currency.
By order of the Board of Governors of the
Federal Reserve System, December 19, 2008.
Jennifer J. Johnson,
Secretary of the Board.
Dated at Washington, DC, this 23rd day of
December 2008.
PO 00000
Frm 00046
Fmt 4701
Sfmt 4703
Federal Deposit Insurance Corporation.
Robert E. Feldman,
Executive Secretary.
Dated: December 11, 2008.
By the Office of Thrift Supervision.
John M. Reich,
Director.
[FR Doc. E8–31116 Filed 1–5–09; 8:45 am]
BILLING CODE 4810–33–P; 6210–01–P; 6714–01–P;
6720–01–P
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Agencies
[Federal Register Volume 74, Number 3 (Tuesday, January 6, 2009)]
[Notices]
[Pages 498-542]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-31116]
[[Page 497]]
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Part II
Department of the Treasury
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Office of the Comptroller of the Currency
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Federal Reserve System
Federal Deposit Insurance Corporation
Department of the Treasury
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Office of Thrift Supervision
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Community Reinvestment Act; Interagency Questions and Answers Regarding
Community Reinvestment; Notice
Federal Register / Vol. 74, No. 3 / Tuesday, January 6, 2009 /
Notices
[[Page 498]]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the Currency
[Docket ID OCC-2008-0027]
FEDERAL RESERVE SYSTEM
[Docket No. OP-1349]
FEDERAL DEPOSIT INSURANCE CORPORATION
DEPARTMENT OF THE TREASURY
Office of Thrift Supervision
[Docket ID OTS-2008-0022]
RIN 3064-AC97
Community Reinvestment Act; Interagency Questions and Answers
Regarding Community Reinvestment; Notice
AGENCIES: Office of the Comptroller of the Currency, Treasury (OCC);
Board of Governors of the Federal Reserve System (Board); Federal
Deposit Insurance Corporation (FDIC); Office of Thrift Supervision,
Treasury (OTS).
ACTION: Notice and request for comment.
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SUMMARY: The OCC, Board, FDIC, and OTS (the agencies) are adopting as
final the Interagency Questions and Answers Regarding Community
Reinvestment (Questions and Answers) that were proposed on July 11,
2007. In response to comments received, the agencies clarified several
of the new and revised questions and answers that were proposed and are
withdrawing the proposed revisions to an existing question and answer.
Also, in response to comments we received, the agencies are proposing a
new question and answer that would provide examples of how an
institution can determine that community services it provides are
targeted to low- and moderate-income individuals. The agencies are also
proposing to revise two existing questions and answers to allow pro
rata consideration in certain circumstances for an activity that
provides affordable housing targeted to low-or moderate-income
individuals. The agencies invite public comment on these proposed new
and revised questions and answers.
DATES: Effective date of amended Interagency Questions and Answers
Regarding Community Reinvestment: January 6, 2009. We request that
comments on the proposed questions and answers be submitted on or
before: March 9, 2009.
ADDRESSES: Comments should be directed to:
OCC: Because paper mail in the Washington, DC area and at the
Agencies is subject to delay, commenters are encouraged to submit
comments by e-mail, if possible. Please use the title ``Community
Reinvestment Act; Interagency Questions and Answers Regarding Community
Reinvestment'' to facilitate the organization and distribution of the
comments. You may submit comments by any of the following methods:
E-mail: regs.comments@occ.treas.gov.
Mail: Office of the Comptroller of the Currency, 250 E
Street, SW., Mail Stop 1-5, Washington, DC 20219.
Fax: (202) 874-4448.
Hand Delivery/Courier: 250 E Street, SW., Attn.: Public
Information Room, Mail Stop 1-5, Washington, DC 20219.
Instructions: You must include ``OCC'' as the agency name and
``Docket ID OCC-2008-0027'' in your comment. In general, OCC will enter
all comments received into the docket without change, including any
business or personal information that you provide such as name and
address information, e-mail addresses, or phone numbers. Comments
received, including attachments and other supporting materials, are
part of the public record and subject to public disclosure. Do not
enclose any information in your comment or supporting materials that
you consider confidential or inappropriate for public disclosure.
You may review comments and other related materials that pertain to
this notice by any of the following methods:
Viewing Comments Personally: You may personally inspect
and photocopy comments at the OCC's Public Information Room, 250 E
Street, SW., Washington, DC. For security reasons, the OCC requires
that visitors make an appointment to inspect comments. You may do so by
calling (202) 874-5043. Upon arrival, visitors will be required to
present valid government-issued photo identification and submit to
security screening in order to inspect and photocopy comments.
Docket: You may also view or request available background
documents and project summaries using the methods described above.
Board: You may submit comments, identified by Docket No. OP-1349,
by any of the following methods:
Agency Web Site: https://www.federalreserve.gov. Follow the
instructions for submitting comments at https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: regs.comments@federalreserve.gov. Include docket
number in the subject line of the message.
Fax: 202-452-3819 or 202-452-3102.
Mail: Jennifer J. Johnson, Secretary, Board of Governors
of the Federal Reserve System, 20th Street and Constitution Avenue,
NW., Washington, DC 20551.
All public comments are available from the Board's Web site at https://
www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm as submitted,
unless modified for technical reasons. Accordingly, your comments will
not be edited to remove any identifying or contact information. Public
comments may also be viewed electronically or in paper in Room MP-500
of the Board's Martin Building (20th and C Streets, NW.) between 9 a.m.
and 5 p.m. on weekdays.
FDIC: You may submit comments, identified by RIN number 3064-AC97
by any of the following methods:
Agency Web site: https://www.fdic.gov/regulations/laws/
federal/propose.html. Follow instructions for submitting comments on
the Agency Web Site.
E-mail: Comments@FDIC.gov. Include the RIN number in the
subject line of the message.
Mail: Robert E. Feldman, Executive Secretary, Attention:
Comments, Federal Deposit Insurance Corporation, 550 17th Street, NW.,
Washington, DC 20429.
Hand Delivery/Courier: Guard station at the rear of the
550 17th Street Building (located on F Street) on business days between
7 a.m. and 5 p.m.
Instructions: All submissions received must include the agency name
and RIN number. All comments received will be posted without change to
https://www.fdic.gov/regulations/laws/federal/propose.html including any
personal information provided.
OTS: You may submit comments, identified by OTS-2008-0022, by any
of the following methods:
E-mail: regs.comments@ots.treas.gov. Please include ID
OTS-2008-0022 in the subject line of the message and include your name
and telephone number in the message.
Fax: (202) 906-6518.
Mail: Regulation Comments, Chief Counsel's Office, Office
of Thrift Supervision, 1700 G Street, NW., Washington, DC 20552,
Attention: OTS-2008-0022.
[[Page 499]]
Hand Delivery/Courier: Guard's Desk, East Lobby Entrance,
1700 G Street, NW., from 9 a.m. to 4 p.m. on business days, Attention:
Regulation Comments, Chief Counsel's Office, Attention: OTS-2008-0022.
Instructions: All submissions received must include the agency name
and docket number for this rulemaking. All comments received will be
entered into the docket and posted on Regulations.gov without change,
including any personal information provided. Comments, including
attachments and other supporting materials received are part of the
public record and subject to public disclosure. Do not enclose any
information in your comment or supporting materials that you consider
confidential or inappropriate for public disclosure.
Viewing Comments Electronically: OTS will post comments on the OTS
Internet Site at https://www.ots.treas.gov/
pagehtml.cfm?catNumber=67&an=1.
Viewing Comments On-Site: You may inspect comments at the Public
Reading Room, 1700 G Street, NW., by appointment. To make an
appointment for access, call (202) 906-5922, send an e-mail to
public.info@ots.treas.gov, or send a facsimile transmission to (202)
906-6518. (Prior notice identifying the materials you will be
requesting will assist us in serving you.) We schedule appointments on
business days between 10 a.m. and 4 p.m. In most cases, appointments
will be available the next business day following the date we receive a
request.
FOR FURTHER INFORMATION CONTACT: OCC: Karen Tucker, National Bank
Examiner, Compliance Policy Division, (202) 874-4428; or Margaret
Hesse, Special Counsel, Community and Consumer Law Division, (202) 874-
5750, Office of the Comptroller of the Currency, 250 E Street, SW.,
Washington, DC 20219.
Board: Anjanette M. Kichline, Senior Supervisory Consumer Financial
Services Analyst, (202) 785-6054; or Brent Lattin, Attorney, (202) 452-
3667, Division of Consumer and Community Affairs, Board of Governors of
the Federal Reserve System, 20th Street and Constitution Avenue, NW.,
Washington, DC 20551.
FDIC: Deirdre Foley, Senior Policy Analyst, Division of Supervision
and Consumer Protection, Compliance Policy Branch, (202) 898-6612; or
Susan van den Toorn, Counsel, Legal Division, (202) 898-8707, Federal
Deposit Insurance Corporation, 550 17th Street, NW., Washington, DC
20429.
OTS: Celeste Anderson, Senior Project Manager, Compliance and
Consumer Protection, (202) 906-7990; or Richard Bennett, Senior
Compliance Counsel, Regulations and Legislation Division, (202) 906-
7409, Office of Thrift Supervision, 1700 G Street, NW., Washington, DC
20552.
SUPPLEMENTARY INFORMATION:
Background
The OCC, Board, FDIC, and OTS implement the Community Reinvestment
Act (CRA) (12 U.S.C. 2901 et seq.) through their CRA regulations. See
12 CFR parts 25, 228, 345, and 563e. The OCC, Board, and FDIC revised
their CRA regulations in a joint final rule published on August 2, 2005
(70 FR 44256) (2005 joint final rule). OTS did not join the agencies in
adopting the August 2005 joint final rule; OTS published separate final
rules on August 18, 2004 (69 FR 51155), March 2, 2005 (70 FR 10023),
April 12, 2006 (71 FR 18614), and March 22, 2007 (72 FR 13429). On July
1, 2007, the March 2007 revisions to OTS's CRA regulation became
effective, making OTS's CRA regulation substantially the same as the
CRA regulations of the OCC, Board, and FDIC.
The agencies' regulations are interpreted primarily through the
``Interagency Questions and Answers Regarding Community Reinvestment''
(Questions and Answers), which provide guidance for use by agency
personnel, financial institutions, and the public. The Questions and
Answers were first published under the auspices of the Federal
Financial Institution Examination Council (FFIEC) in 1996 (61 FR
54647), and were revised on July 12, 2001 (2001 Questions and Answers)
(66 FR 36620).
Subsequent to the adoption of the 2005 joint final rule, the OCC,
Board, and FDIC, after notice and public comment, published new
guidance in the form of questions and answers on March 10, 2006 (71 FR
12424) (2006 Questions and Answers). The 2006 Questions and Answers
addressed primarily matters related to the 2005 joint final rule. On
September 5, 2006, after notice and public comment, OTS published new
guidance in the form of questions and answers pertaining to the revised
definition of ``community development'' and certain other provisions of
the CRA rule common to all four agencies (OTS's September 2006
Questions and Answers). 71 FR 52375.
On July 11, 2007, the agencies published for comment proposed
guidance, which updated and revised the 2001 Questions and Answers and
combined the 2006 Questions and Answers and OTS's September 2006
Questions and Answers. The proposal also introduced nine proposed new
questions and answers (Q&As). 72 FR 37922. OTS also proposed four new
and revised Q&As that the OCC, Board, and FDIC had adopted in the 2006
Questions and Answers, primarily relating to intermediate small savings
associations.
Together, the agencies received comments from 58 different parties.
The commenters represented financial institutions and their trade
associations, community development advocates and organizations,
members of Congress, and others.
As discussed below, this document adopts the nine new Q&As that
were proposed in 2007, with revisions, as appropriate, in response to
comments received. The agencies are also adopting, with minor
revisions, as appropriate, all but one of the proposed revised Q&As.
The agencies are withdrawing the proposed revisions to Q&A Sec. --
--.23(e)-2.
The agencies also are proposing one new and two revised Q&As, which
are discussed below. These proposed Q&As have been developed in
response to comments received by the agencies.
The Interagency Questions and Answers are grouped by the provision
of the CRA regulations that they discuss, are presented in the same
order as the regulatory provisions, and employ an abbreviated method of
citing to the regulations. For example, the small bank performance
standards for national banks appear at 12 CFR 25.26; for Federal
Reserve System member banks supervised by the Board, they appear at 12
CFR 228.26; for state nonmember banks, they appear at 12 CFR 345.26;
and for thrifts, the small savings association performance standards
appear at 12 CFR 563e.26. Accordingly, the citation would be to 12
CFR----.26. Each Q&A is numbered using a system that consists of the
regulatory citation and a number, connected by a dash. For example, the
first Q&A addressing 12 CFR----.26 would be identified as Sec. --
--.26-1.
Although a particular Q&A may be found under one regulatory
provision, e.g., 12 CFR----.22, which relates to the lending test
applicable to large institutions, its content may also be applicable
to, for example, small institutions, which are evaluated pursuant to
small institution performance standards found at 12 CFR----.26. Thus,
readers with a particular interest in small institution issues, for
example, should also consult the guidance that describes the lending,
investment, and service tests.
The Questions and Answers are indexed to aid readers in locating
specific information in the document.
[[Page 500]]
The index contains keywords, listed alphabetically, along with
numerical indicators of questions and answers that relate to that
keyword. The list of Q&As addressing each keyword in the index is not
intended to be exhaustive. We welcome suggestions for additional
entries to the index.
Discussion of the Q&As Being Adopted as Final
New Q&As Proposed in 2007
I. Investments in minority- or women-owned financial institutions
and low-income credit unions. The agencies proposed a new Q&A Sec. --
--.12(g)-4 that would interpret the statutory provision that allows the
agencies to consider as a factor a majority-owned financial
institution's activities in cooperation with a minority- or women-owned
financial institution or low-income credit union. See 12 U.S.C.
2903(b). Twenty-five commenters addressed the new Q&A as proposed.
Although five commenters believed that the proposed guidance went
directly against the intent of the CRA regulations, the rest of the
commenters were generally in favor of the new Q&A. Several commenters,
however, suggested additions or modifications that could be made to the
guidance.
We are modifying the proposed Q&A to address some of these
comments. Four commenters urged the agencies to allow consideration of
activities in cooperation with minority- or women-owned financial
institutions or low-income credit unions only if the majority-owned
institution had adequately addressed the credit needs of its assessment
area(s). The agencies believe that the statute currently does not
impose such a limitation. However, in response to the comment, we have
clarified that the impact of such activities on a majority-owned
institution's rating will be determined in conjunction with an
assessment of its overall performance in its assessment area(s).
Two commenters specifically asked the agencies to provide examples
of ``other ventures'' that could receive consideration if engaged in by
a majority-owned financial institution in cooperation with a minority-
or women-owned financial institution or low-income credit union.
Several examples of ``other ventures'' have been added to the answer.
Six commenters suggested that activities in cooperation with
community development financial institutions (CDFIs) should be allowed
the same broader geographic allowance that the statute allows for
activities in cooperation with minority- or women-owned financial
institutions or low-income credit unions. The statute does not provide
a similar provision for activities in cooperation with CDFIs. Because
the statute and regulation otherwise generally focus on a financial
institution's activities that benefit its local community, the agencies
do not believe it is appropriate to apply the relaxed geographic
requirement to CDFIs or other entities.
One other commenter suggested that the agencies should delete the
final sentence of the proposed Q&A: ``The activities must, however,
help meet the credit needs of the local communities in which the
minority- or women-owned institutions or low-income credit unions are
chartered.'' The commenter's concern was that this sentence might be
read to require the majority-owned financial institution to prove that
its involvement with the minority- or women-owned institution or low-
income credit union ultimately can be directly linked to a specific
CRA-related activity of the minority bank. The CRA statute specifically
conditions consideration of activities in cooperation with minority- or
women-owned institutions or low-income credit unions on those
activities helping to meet the credit needs of the local communities in
which the minority- or women-owned institutions or low-income credit
unions are chartered. Therefore, the sentence has not been removed. The
majority-owned financial institution should have a general
understanding, prior to engaging in an activity in cooperation with a
minority- or women-owned institution or low-income credit union, about
how the activity will help to meet the credit needs of the community in
which the minority- or women-owned institution or low-income credit
union is chartered; however, no specific type of proof is required.
II. Intermediate small institutions' affordable home mortgage loans
and small business and small farm loans. The agencies received eleven
comments addressing proposed new Q&A Sec. ----.12(h)-3, which would
allow an intermediate small institution to select certain home
mortgage, small business, and small farm loans, which are not required
to be reported under the CRA or Home Mortgage Disclosure Act (HMDA)
regulations, to be considered as community development loans. All of
the commenters supported the proposed Q&A.
The agencies are adopting the Q&A with clarifying revisions based
on commenters' questions and suggestions. For example, one commenter
asked whether an intermediate small institution's voluntary reporting
of small business or small farm loan data would disqualify it from the
optional selection of some of those loans as community development
loans. The guidance clarifies that optional reporting of small business
or small farm loan data will not prevent an intermediate small
institution from choosing some of those loans to be considered as
community development loans unless the intermediate small institution
opts to be evaluated under the lending, investment, and service tests
applicable to large institutions.
One commenter asked whether an intermediate small institution that
is required to report home mortgage lending under HMDA would be able to
opt to have some of its home mortgage loans considered as community
development loans. Because the home mortgage loans are required to be
reported under HMDA, they may be considered only as home mortgage loans
(unless they are multifamily dwelling loans).
The guidance has also been revised to clarify that an intermediate
small institution may select individual loans (other than home mortgage
loans reported under HMDA) to be considered as community development
loans. An institution need not select an entire portfolio for
consideration as community development loans.
The agencies note that intermediate small institutions that opt to
have certain home mortgage, small business, and small farm loans
considered as community development loans should notify their examiners
which loans it has elected for this consideration prior to or at the
start of their CRA examinations.
III. Examples of ``other loan data.'' The agencies received
seventeen comments addressing proposed new Q&A Sec. ----.22(a)(2)-4,
which listed examples of ``other loan data'' that would be considered
under the lending test. Most of the commenters supported the proposed
Q&A. However, a number of commenters suggested that some of the types
of ``other loan data'' should be treated the same as direct lending.
Several commenters asserted that letters of credit should be
treated as loan originations. They noted that, although letters of
credit are not immediately (if ever) funded, the institution must
underwrite them in the same way direct loans are underwritten and must
also ensure that funds are available for eventual funding. Further,
many community development projects would not be financed without the
back-up support provided by a financial
[[Page 501]]
institution's letter of credit. For these reasons, commenters urged
that letters of credit be considered as loan originations.
The CRA regulations provide that letters of credit will be
considered as ``other loan data.'' The agencies cannot change treatment
of letters of credit in the regulations through interpretation.
However, the agencies will consider the issue again in the event they
undertake more comprehensive changes to the CRA regulations. The
agencies also plan to remind examiners that letters of credit may
deserve specific mention in the narrative of an institution's public
performance evaluation.
Commenters also asserted that an institution's loans for mixed-
income housing should not be considered under ``other loan data.''
Instead, commenters proposed that institutions should receive
consideration for such loans (or investments) that enable community
development, such as mixed-income projects that have an affordable
housing component, as community development loans (or qualified
investments).
The agencies are adopting Q&A Sec. ----.22(a)(2)-4 as proposed.
However, as discussed below, we are also proposing for comment a
revised Q&A Sec. ----.12(h)-8 discussing what is meant by a ``primary
purpose of community development.'' If this proposed revision is
adopted as final, ``loans that do not have a primary purpose of
community development, but where a certain amount or percentage of
units is set aside for affordable housing'' would be deleted from the
list of examples of ``other loan data'' because these would be covered
in that revised guidance which would allow an institution to receive
pro rata consideration for the portion of a loan or investment that
helps to provide affordable housing to low- or moderate-income
individuals. In the meantime, however, institutions may continue to
present such loans to examiners as ``other loan data.''
IV. Purchased loan participations. Ten commenters addressed
proposed Q&A Sec. ----.22(a)(2)-6, which clarified that the purchase
of a loan participation is treated as the purchase of a loan. The
majority of the commenters supported the proposed guidance; however,
one commenter expressed concern that loans could be resold numerous
times merely to inflate their value for CRA evaluation purposes. We
have modified this Q&A to clarify that examiners will consider whether
loan participations (and other loan purchases) have been resold merely
to inflate their value for CRA purposes when they evaluate an
institution's lending activity.
V. Small business loans secured by a one-to-four family residence.
The agencies proposed Sec. ----.22(a)(2)-7 to provide guidance about
small business and small farm loans where a dwelling serves as
collateral. As discussed in the supplementary information published
with the proposed guidance, the new Q&A was called for because of
changes to the Board's Regulation C regarding the treatment of
refinancings of home mortgage loans. See 72 FR at 37925. We received
twelve comments addressing this proposed Q&A, primarily in support of
the proposed Q&A. We are adopting the Q&A as proposed.
VI. Investments in a national or regional fund. The agencies
proposed Q&A Sec. ----.23(a)-2 to clarify how an institution that
makes a loan or investment in a national or regional community
development fund may demonstrate that the investment meets the
geographic requirements of the CRA regulation. The proposed Q&A
suggested alternative methods for documenting that the investment was
intended to benefit the institution's assessment area.
Thirty-three commenters addressed this guidance. One theme in many
of the comments was that investments in national funds should be
treated in the same manner as statewide or regional funds. The
regulations state that the investment test evaluates an institution's
record of helping to meet the credit needs of its assessment area(s)
through qualified investments that benefit its assessment area(s) or a
broader statewide or regional area that includes the institution's
assessment area(s). See 12 CFR 25.23(a), 228.23(a), 345.23(a), and
563e.23(a). Investments in nationwide funds, like investments in other
funds, are subject to these standards. An institution may wish to
provide documentation from a nationwide fund to demonstrate the
geographic benefit to the institution's assessment area(s) or the
broader statewide or regional area that includes its assessment
area(s).
Because the proposed Q&A addressed investments in both national and
regional funds, some commenters were confused about the types of
investments the agencies intended to address in the proposed Q&A. The
proposed Q&A was intended to address investments in nationwide funds or
in any fund that is not limited to the statewide or regional area that
includes the institution's assessment area(s). Because other existing
Q&As address investments in statewide and regional funds, Q&A Sec. --
--.23(a)-2 has been revised to address specifically investments in
``nationwide'' funds. Institutions that invest in statewide or regional
funds should refer to Q&As Sec. ----.12(h)-6 and Sec. ----.12(h)-7
for guidance. The guidance in these Q&As has not been changed.
Commenters also addressed a number of other issues. One commenter
believed that the requirements in the proposed Q&A for an investment in
a nationwide fund were more rigorous than the regulations required, in
that the proposed Q&A focused on benefit to an institution's assessment
area, without also considering benefit to the broader statewide or
regional area that includes the institution's assessment area(s). The
Q&A has been revised to clarify that investments in nationwide funds
will be reviewed to determine whether they directly or indirectly
benefit one or more of an institution's assessment areas or a broader
statewide or regional area that includes the institution's assessment
area(s).
Several commenters understood the proposal to suggest that the
documentation methods put forward in the proposed Q&A was an exclusive,
mandatory list. The agencies have clarified the final Q&A to provide
that the documentation methods identified are among those that may, at
the institution's option, be provided. The agencies will accept any
information provided by an institution that reasonably demonstrates
that the purpose, mandate, or function of a nationwide fund includes
serving geographies or individuals located within the institution's
assessment area(s) or a broader statewide or regional area that
includes its assessment area(s). Typically, information about where a
fund's investments are expected to be made or targeted often will be
found in the fund's prospectus, or other documents provided by the fund
prior to or at the time of the institution's investment, and the
institution, at its option, may provide such documentation in
connection with its CRA evaluation.
Some commenters also asserted that institutions should receive
consideration for the full dollar amount of any investment in a
nationwide fund if at least one project in which the fund invests is
located in the institution's assessment area or the broader statewide
or regional area that includes the institution's assessment area. The
agencies have not incorporated this specific recommendation into the
text of the Q&A. The agencies believe that the final Q&A provides
sufficient flexibility to address a variety of different circumstances,
given the evolving nature and significance of nationwide funds.
[[Page 502]]
VII. Examination as an intermediate small institution. Proposed new
Q&A Sec. ----.26(a)(2)-1 clarified that there is no lag period between
becoming an intermediate small institution and being examined as an
intermediate small institution. Eight commenters addressed this new
guidance; all were supportive. The agencies are adopting this new Q&A
as proposed.
Several commenters suggested that the agencies should provide
technical assistance to small institutions that are about to become
intermediate small institutions at the institutions' request. The
agencies currently provide technical assistance to small institutions
in transition to becoming ``intermediate small'' institutions.
VIII. Reporting of a participation in a community development loan.
The agencies proposed Q&A Sec. ----.42(b)(2)-4 to clarify that
institutions that purchase community development loan participations
should report only the amount of their purchase. The supplementary
information published with the proposal noted that the requirement to
report only the dollar amount of the participation purchased for
community development loans differs from the requirements for reporting
small business and small farm loan participations. When an institution
reports participations or purchases of small business and small farm
loans, it must report the entire loan amount at origination.
Eight commenters addressed this proposed Q&A. One commenter
recommended the agencies adopt consistent requirements governing the
way loans are reported. Another commenter noted that different
requirements may be appropriate because reporting the purchased amount
of the loan more accurately reflects the actual dollar amount of an
institution's community development lending. After consideration of the
comments received, the agencies are adopting the Q&A as proposed
because the agencies believe that reporting the amount purchased,
rather than the amount at origination, more accurately portrays the
institution's involvement in community development lending.
IX. Refinanced or renewed community development loans. The agencies
proposed Q&A Sec. ----.42(b)(2)-5 to clarify that institutions should
collect information about community development loans that they
refinance or renew as loan originations. The Q&A also notes that,
generally, the same limitations that apply to the reporting of
refinancings and renewals of small business and small farm loans apply
to the reporting of refinancings and renewals of community development
loans. For example, an institution may only report one origination
(including a renewal or refinancing treated as an origination) per loan
per year, unless an increase in the loan amount is granted. Eight
commenters commented on, and supported adoption of this proposed Q&A.
The agencies are adopting the Q&A as proposed.
Revised Q&As Proposed in 2007 That Were Specifically Described in the
Supplementary Information
I. Activities that promote economic development. The agencies
proposed to revise Q&A Sec. ----.12(g)(3)-1, which describes the types
of activities that promote economic development by financing small
businesses and small farms. The revisions clarified the language of the
guidance, and added loans to or investments in Rural Business
Investment Companies (RBICs) and New Markets Tax Credit-Eligible
Community Development Entities (CDEs) as types of loans or investments
that the agencies will presume to promote economic development.
Fourteen commenters addressed these proposed revisions, including five
that represented community development financial institutions (CDFIs).
All fourteen commenters supported adoption of the proposed revisions.
The agencies are adopting the revised Q&A as proposed.
CDFI representative commenters urged the agencies to also presume
that loans to or investments in CDFIs promote economic development. Q&A
Sec. ----.12(g)(3)-1 applies only to the prong of the definition of
``community development'' addressing promoting economic development by
financing small businesses and small farms. The agencies have not
adopted this suggestion. Existing Q&A Sec. ----.12(t)-4 lists as
examples of qualified investments ``investments, grants, deposits, or
shares in or to * * * CDFIs that primarily lend or facilitate lending
in low- and moderate-income areas or to low- and moderate-income
individuals in order to promote community development, such as a CDFI
that promotes economic development on an Indian reservation.'' In
addition, if a CDFI were engaged in activities that promote economic
development by financing small businesses or small farms, investments
in or loans to the CDFI would have a primary purpose of community
development.
II. Examples of community development loans. The agencies proposed
to revise Q&A Sec. ----.12(h)-1, which provides examples of community
development loans, to add a loan to a New Markets Tax Credit-Eligible
CDE as an example of a community development loan. The agencies also
proposed to revise this Q&A by adding a new bullet explaining that
another example of a community development loan is a loan in an amount
greater than $1 million to a business, when the loan is made as part of
the Small Business Administration's 504 Certified Development Company
program. The three commenters that addressed the proposed revisions to
this Q&A recommended that they be adopted. The agencies are adopting
this Q&A as proposed.
III. Examples of community development services. The agencies
proposed to revise Q&A Sec. ----.12(i)-3, which lists examples of
community development services, to add as a new example of a community
service ``increasing access to financial services by opening or
maintaining branches and other facilities that help to revitalize or
stabilize a low- or moderate-income geography, a designated disaster
area, or a distressed or underserved nonmetropolitan middle-income
geography, unless the opening or maintaining of such branches or other
facilities has been considered in the evaluation of the institution's
retail banking services under 12 CFR ----.24(d).'' The agencies also
proposed to revise this Q&A to highlight that credit counseling that
can assist borrowers in avoiding foreclosure on their homes would be a
community development service. Finally, the agencies proposed to add
individual retirement accounts (IDAs) and free payroll check cashing
services that increase access to financial services for low- or
moderate-income individuals to the examples of financial services with
the primary purpose of community development.
The agencies received ten comments addressing these proposed
revisions. All of the commenters generally favored adopting the
proposed revisions. The agencies are adopting the proposed Q&A with
several revisions.
One commenter suggested that the reference to ``free'' check
cashing should be changed to ``affordable'' or ``low-cost'' check
cashing services that increase access to financial services for low- or
moderate-income individuals. The agencies have revised the Q&A to
reference free and low-cost check cashing. In addition, the agencies
have clarified that low-cost bank accounts can be either savings or
checking accounts.
To help to address current economic conditions and issues, the
agencies have added an additional example of a
[[Page 503]]
community development service: Foreclosure prevention programs to low-
or moderate-income homeowners who are facing foreclosure on their
primary residence with the objective of providing affordable,
sustainable, long-term loan modifications and restructurings. The
agencies have also clarified that, to qualify as a community
development service, credit counseling to assist borrowers in avoiding
foreclosure on their homes should be targeted to low- and moderate-
income borrowers, based on the definition of community development at
12 CFR ---- .12(g)(2).
Finally, in the proposed Q&A, an existing bullet addressing school
savings programs and financial education was split into two separate
bullets. This change has not been adopted; however, the agencies are
adopting a minor revision incorporating the commonly used term,
``financial literacy,'' to the bullet.
IV. Federal Home Loan Bank (FHLB) unpaid dividends. The agencies
proposed to revise Q&A Sec. ----.12(t)-3 to clarify that funds
retained by FHLBs to support the Affordable Housing Program (AHP),
rather than being paid out to investor financial institutions as
dividends, are not qualified investments by the financial institutions.
The agencies received three comments addressing this proposed revision.
One commenter supported confirmation of the existing policy. The other
two commenters were concerned that this position may have the
unintended effect of creating a disincentive for FHLB member
institutions to participate in the AHP and, ultimately, undermine
industry support for the program. The agencies considered this comment,
but still believe that funds that are retained by the FHLBs are not
qualified investments by the financial institutions that do not receive
them as dividends. The Q&A continues to point out that institutions'
other activities in connection with the FHLBs' AHP program would be
considered in an institution's CRA evaluation--for example, providing
technical assistance to applicants would be considered as a community
development service. The agencies are adopting this Q&A as proposed.
V. Examples of qualified investments. The agencies proposed to
revise Q&A Sec. ----.12(t)-4, which lists examples of qualified
investments, to add an investment in a New Markets Tax Credit-Eligible
CDE as an additional example. The proposal also would have added as an
example of a qualified investment an investment in a community
development venture capital company that promotes economic development
by financing small businesses. The agencies received two comments on
these proposed revisions, which recommended adoption. The Q&A is being
adopted as proposed.
VI. Small institution adjustment. The agencies proposed to revise
Q&A Sec. ----.12(u)(2)-1, which provides information about the annual
adjustments to the asset-size thresholds for small institutions and
intermediate small institutions, to refer the reader to the FFIEC's Web
site for historical and current asset-size threshold information. The
two commenters that addressed this proposed change supported its
adoption. The agencies are adopting the Q&A as proposed.
VII. Responsive lending activities. The agencies proposed to revise
Q&A Sec. ----.22(a)-1, which discusses types of lending activities
that may warrant favorable consideration as being responsive to the
credit needs of the institution's assessment area(s). The proposed
revision highlighted that establishing loan programs that provide
relief to low- and moderate-income homeowners who are facing
foreclosure is a lending activity that would warrant consideration as
being responsive to the needs of an institution's assessment areas. The
agencies received six comments addressing this proposed revision. All
supported the proposed revision.
The agencies are adopting the proposed revised Q&A with clarifying
changes. First, the agencies have provided examples of the types of
loan programs that provide relief from foreclosure, e.g., establising
loan programs with the objective of providing affordable, sustainable,
long-term relief through refinancings, restructures, or modifications.
Second, the word, ``homes,'' has been replaced by ``primary
residences'' to clarify the scope of the Q&A.
In April 2007, the agencies issued a joint statement entitled,
``Statement on Working With Mortgage Borrowers.'' In that statement,
the agencies encouraged institutions to work with borrowers who are
financially unable to make their contractual payment obligations on
their home loans. The statement noted that financial institutions may
receive favorable CRA consideration for programs that transition low-
and moderate-income borrowers from higher cost loans to lower cost
loans, provided the loans are made in a safe and sound manner.
Consistent with the statement, the proposed Q&A addressed only loan
programs that provide relief to low- and moderate-income homeowners who
are facing foreclosure as a type of lending activity that would warrant
consideration as being responsive to the credit needs of an
institution's assessment areas. However, under the regulation, the
agencies assess an institution's responsiveness to credit needs in each
of its assessment area(s). See 12 CFR parts 25, 228, 345 and 563e at
App. A(b)(1)(i). The agencies believe that foreclosure assistance to
homeowners who are facing foreclosure on their primary residences would
be responsive to the needs of an institution's assessment area(s).
Therefore, the agencies have revised the final Q&A to refer to
``homeowners'' generally.
VIII. Constraints on affiliate lending. Q&A Sec. ----.22(c)(2)(i)-
1 provides that an affiliate may not claim a loan origination or loan
purchase for CRA purposes if another institution claims the same loan
origination or loan purchase. The agencies proposed to revise this Q&A
to add an example and to clarify that the guidance applies to all
institutions, whether they are subject to the lending test, small
institution examination standards, or the community development test
applicable to wholesale or limited purpose institutions. Six commenters
addressed these proposed revisions.
Two commenters supported the clarifications. Four commenters
expressed concern that the new example appears to give ``double
credit'' for one loan because the purchasing institution is an
affiliate of the originator. Each financial institution that is subject
to CRA is separately evaluated for its CRA performance, regardless of
whether it has affiliates that are also institutions subject to the
CRA. The CRA regulations provide that the agencies will consider both
loan originations and loan purchases when evaluating an institution's
CRA performance. To address commenters' concerns about sales of loans
merely to inflate their value for CRA purposes, however, the agencies
are adopting the revised Q&A with a new cross reference to Q&As Sec.
----.22(c)(2)(ii)-1 and Sec. ----.22(c)(2)(ii)-2. These Q&As provide
that the manner in which loans are allocated among affiliated
institutions for CRA purposes must reflect actual business decisions
about the allocation of banking activities, and should not be designed
solely to enhance their CRA evaluations.
IX. Retail banking services delivery systems. The agencies proposed
to revise Q&A Sec. ----.24(d)-1, which explains how examiners evaluate
the availability of an institution's systems for delivering retail
banking services.
[[Page 504]]
The proposed revision would conform the existing Q&A to more closely
track the service test performance criteria in the regulations. The
agencies received only one comment on the proposed revisions to this
Q&A, which supported the clarifications to the Q&A. The agencies are
adopting the revised Q&A as proposed.
X. Assessment areas may not extend substantially beyond
metropolitan statistical area (MSA) boundaries. The agencies proposed
to revise Q&As Sec. ----.41(e)(4)-1 and Sec. ----.41(e)(4)-2, which
address the maximum size of an assessment area, to adopt the revised
terminology in the Standards for Defining Metropolitan and Micropolitan
Statistical Areas adopted by the Office of Management and Budget, and
to incorporate guidance that the agencies provided in connection with
the technical corrections made to the CRA regulations in 2005. See 70
FR 15570. The two comments on these proposed revisions supported
adopting them. The agencies are adopting the revised Q&As as proposed.
XI. Reporting data under the CRA regulations. The agencies proposed
to revise Q&A Sec. ----.42-1, which addresses when an institution must
collect and report data, to refer generally to the definition of a
small institution, rather than to the current dollar amount of the
asset threshold of such institutions, because the asset threshold is
revised annually. The agencies also revised the mailing address in the
Q&A. The agencies received no comments on these proposed revisions. The
revised Q&A is being adopted as proposed.
XII. Reporting home equity lines of credit for both home
improvement and business purposes. The agencies proposed to revise Q&A
Sec. ----.42(a)-7, which addresses the reporting of a home equity line
of credit, used in part for home improvement purposes and used in part
for small business purposes, to make the Q&A consistent with changes
that were made to the Board's Regulation C requirements. The agencies
received only one comment addressing the proposed revised Q&A in
support of the proposed revision. The agencies are adopting the revised
Q&A as proposed.
XIII. Participations in small business or small farm loans. The
agencies proposed to revise Q&A Sec. ----.42(a)(2)-1, which provides
guidance regarding the reporting of the amount of a small business or
small farm loan that an institution purchases, to clarify that the
guidance also applies to purchases of small business or small farm loan
participations. The agencies received five comments addressing this
proposed revision. One commenter agreed that the reporting of loan
participations purchased should be treated in the same manner as the
reporting of whole loans purchased. The other four commenters addressed
the inconsistency between the reporting requirements for small business
and small farm loan purchases (either whole loans or participations in
loans) and the reporting requirements for community development loan
purchases (whole or partial). As discussed above, the CRA regulations
at 12 CFR ----.42(a)(2) require the reporting of the loan amount at
origination when reporting small business and small farm loan data.
Thus, the agencies are adopting the revised Q&A as proposed.
Withdrawal of Proposed Revisions to Existing Q&A Sec. ----.23(e)-2
Q&A Sec. ----.23(e)-2 addresses how examiners evaluate an
institution's qualified investment in a fund with a primary purpose of
community development. The agencies proposed to revise the Q&A's
discussion of consideration of legally binding commitments recorded by
the institution according to GAAP. The agencies received two comments,
both of which opposed the change. In response to these comments, and
because the proposal was inconsistent with an interagency CRA
interpretive letter published by the agencies in 1997 (OCC I.L. No. 800
(Sept. 11, 1997)), the agencies are withdrawing the proposal.
Therefore, when evaluating a financial institution, examiners will
continue to include in the dollar amount of qualified investments any
legally binding commitments recorded by the institution according to
GAAP.
Clarifying Revisions to Existing Q&As
Q&A Sec. ----.12(g)-3
Three commenters addressed Q&A Sec. ----.12(g)-3, which addresses
flexibility in considering performance in high-cost areas. Q&A Sec. --
--.12(g)-3 provides an example of a situation when examiners could take
into account the high cost of housing when an institution provides a
community development loan or qualified investment to an organization
that assists middle-income, as well as low- and moderate-income, people
and areas. Even though the agencies had not proposed revisions to this
existing guidance, after consideration of the comments, the agencies
are revising this Q&A by adding a cross reference to Q&A Sec. --
--.12(h)-8, which provides information on ``primary purpose'' of
community development.
Q&A Sec. ----.12(g)(4)(i)-1
The agencies did not receive any comments directly mentioning Q&A
Sec. ----.12(g)(4)(i)-1. However, several commenters expressed their
general support for the additional foreclosure prevention references
that were proposed in other Q&As. Q&A Sec. ----.12(g)(4)(i)-1
addresses activities that are considered to ``revitalize or stabilize''
a low- or moderate-income geography. Based on these comments, the
following example has been added to the answer: ``For example,
providing foreclosure prevention programs with the objective of
providing affordable, sustainable, long-term loan restructurings or
modifications to homeowners in low- and moderate-income geographies,
consistent with safe and sound banking practices, may help to
revitalize or stabilize those geographies.''
OTS Request for Comments on Conforming Revisions
OTS specifically requested comment on several Q&As that it proposed
to conform OTS guidance to guidance previously adopted by the OCC,
Board, and FDIC. Five commenters addressed OTS's conforming revisions.
They unanimously supported the efforts of OTS to be consistent with the
other agencies. OTS is adopting the Q&As as proposed.
Revised and New Q&As Being Proposed for Comment
Proposed New Q&A: Community Services Targeted to Low- or Moderate-
income Individuals
In response to suggestions made by commenters, the agencies are
proposing a new Q&A that would provide examples of ways an institution,
which provides community services, could determine that the community
services are targeted to low- and moderate-income individuals when the
institution does not know the actual income of the individuals. The
text of the proposed Q&A follows:
[rtrif]Sec. ----.12(g)(2)- 1: Community development includes
community services targeted to low- or moderate-income individuals.
What are examples of ways that an institution could determine that
community services are offered to low- or moderate-income individuals?
A1: Examples of ways in which an institution could determine that
community services are targeted to low- or moderate-income persons
include:
The community service is targeted to the clients of a
nonprofit organization that has a defined mission of serving
[[Page 505]]
low- and moderate-income persons, or, because of government grants, for
example, is limited to offering services only to low- or moderate-
income persons.
The community service is offered by a nonprofit
organization that is located in and serves a low- or moderate-income
geography.
The community service is conducted in a low- or moderate-
income area and targeted to the residents of the area.
The community service is offered at a workplace to workers
who are low- and moderate-income, based on readily available data for
the average wage for workers in that particular occupation or industry
(see, e.g., https://www.bls.gov/bls/blswage.htm (Bureau of Labor
Statistics)).[ltrif]
Proposed Revised Q&As: Primary Purpose of Community Development
As discussed above, a number of commenters suggested that loans or
investments that provide some affordable housing to low- or moderate-
income individuals should be considered as ``community development.''
The regulations require community development activities to have a
``primary purpose of community development.'' See 12 CFR----.12(h), --
--.12(i), and .12(t).
Q&A Sec. ----.12(h)-8 generally provides two methods of
determining whether an activity has a primary purpose of community
development: (1) If a majority of the dollars or beneficiaries of the
activity are identifiable to one or more of the enumerated community
development purposes, then an activity will be considered to possess
the requisite primary purpose; and (2) If the express, bona fide intent
of the activity, as stated, for example, in a prospectus, loan
proposal, or community action plan, is primarily one or more of the
enumerated community development purposes; the activity is specifically
structured (given any relevant market or legal constraints or
performance context factors) to achieve the expressed community
development purpose; and the activity accomplishes, or is reasonably
certain to accomplish, the community development purpose involved, then
the requisite primary purpose may be found.
The agencies have generally indicated that if an activity has a
primary purpose of community development (determined by either method
above), the entire investment, loan, or service would be considered in
an institution's CRA evaluation. However, if an activity does not have
a primary purpose of community development applying these standards,
then it would not be considered as a qualified investment, community
development loan, or community development service.
The agencies are proposing to revise Q&A Sec. ----.12(h)-8 to
allow consideration for an activity that provides some affordable
housing targeted to low- or moderate-income individuals, but where it
would not be deemed to have a primary purpose of community development
measured by a majority of the entire activity's benefits or dollar
value, or by relying on the express purpose of the activity. The Q&A
would specifically allow activities related to the provision of mixed-
income housing, such as in connection with a development that has a
mixed-income housing component or an affordable housing set-aside
required by federal, state, or local government, to be eligible for
consideration as an activity that has a ``primary purpose'' of
community development at the election of the institution. In those
cases, an institution would receive pro rata consideration for the
portion of the activity that helps to provide affordable housing to
low- or moderate-income individuals.
The text of the proposed revised Q&A follows:
Sec. ----.12(h)--8: What is meant by the term ``primary purpose''
as that term is used to define what constitutes a community development
loan, a qualified investment, or a community development service?
A8. A loan, investment, or service has as its primary purpose
community development when it is designed for the express purpose of
revitalizing or stabilizing low- or moderate-income areas, designated
disaster areas, or underserved or distressed nonmetropolitan middle-
income areas, providing affordable housing for, or community services
targeted to, low- or moderate-income persons, or promoting economic
development by financing small businesses and farms that meet the
requirements set forth in 12 CFR ----.12(g). To determine whether an
activity is designed for an express community development purpose, the
agencies apply one of two approaches. First, if a majority of the
dollars or beneficiaries of the activity are identifiable to one or
more of the enumerated community development purposes, then the
activity will be considered to possess the requisite primary purpose.
Alternatively, where the measurable portion of any benefit bestowed or
dollars applied to the community development purpose is less than a
majority of the entire activity's benefits or dollar value, then the
activity may still be considered to possess the requisite primary
purpose[rtrif], and the institution may receive CRA consideration for
the entire activity,[ltrif] if (1) The express, bona fide intent of the
activity, as stated, for example, in a prospectus, loan proposal, or
community action plan, is primarily one or more of the enumerated
community development purposes; (2) the activity is specifically
structured (given any relevant market or legal constraints or
performance context factors) to achieve the expressed community
development purpose; and (3) the activity accomplishes, or is
reasonably certain to accomplish, the community development purpose
involved.
[rtrif]Generally, a loan, investment, or service will be determined
to have a ``primary purpose'' of community development only if it meets
the criteria described above. However, an activity also may be deemed
to have a ``primary purpose'' of community development in certain other
limited circumstances in which these criteria have not been met.
Specifically, activities related to the provision of mixed-income
housing, such as in connection with a development that has a mixed-
income housing component or an affordable housing set-aside required by
federal, state, or local government, also would be eligible for
consideration as an activity that has a ``primary purpose'' of
community development at the election of the institution. In such
cases, an institution may receive pro rata consideration for the
portion of such activities that helps to provide affordable housing to
low- or moderate-income individuals. For example, if an institution
makes a $10 million loan to finance a mixed-income housing development
in which ten percent of the units will be set aside as affordable
housing for low- and moderate-income individuals and ten percent of the
funds will be used for the cost of constructing those units, the
institution may elect to treat $1 million of such loan as a community
development loan.[ltrif]
The fact that an activity provides indirect or short-term benefits
to low- or moderate-income persons does not make the activity community
development, nor does the mere presence of such indirect or short-term
benefits constitute a primary purpose of community development.
Financial institutions that want examiners to consider certain
activities (under either approach) should be prepared to demonstrate
the activities' qualifications.
Because this proposed revision would be a significant change to the
agencies'
[[Page 506]]
general ``all or nothing'' CRA consideration policy for community
development loans, qualified investments, and community development
services, the agencies solicit public comment on the proposed revision.
We specifically request comment on the following:
Will the proposed revision, allowing pro rata CRA
consideration for low- and moderate-income housing set-asides, spur the
construction and rehabilitation of housing for low- and moderate-income
persons? Why or why not?
Should the special pro rata consideration be restricted
only to instances where a governmental entity requires a set aside of a
certain number or percentage of units as housing affordable for low- or
moderate-income housing (as opposed to voluntary designation of low-
and moderate-income units by a developer)?
How should the amount of the pro rata share be determined
for reporting purposes--should institutions be required to report the
actual funds attributable to the targeted units or should they report a
proportional share, based on the percentage of set-aside units? For
example, if an institution makes a $1 million loan for a development in
which ten percent of the units are set aside as affordable housing for
low- or moderate-income individuals, but only six percent of the loan
proceeds are used to construct the units, should the intitution report
ten percent of the total amount of the loan ($1 million) or six percent
($600,000)?
Should the pro rata treatment apply only to affordable
housing or should institutions also be able to receive pro rata
treatment for loans or investments with other community development
purposes?
Would this change in policy lead to unjustifiable
inflation of community development activities?
If the proposed revision to Q&A Sec. ----.12(h)-8, above, is
adopted, the agencies would also revise Q&A Sec. ----.42(b)(2)-3 to
address data collection and reporting of the pro rata share of the
mixed-income housing loans described in the Q&A. If an institution were
to elect to have the portion of mixed-income housing loans set aside
for low- or moderate-income housing considered as community development
loans, in order to receive consideration for such loans, the
institution would need to collect and report data on only the portions
of the loans that provide housing for low- or moderate-income
individuals. The proposed revision to Q&A Sec. ----.42(b)(2)-3
follows:
Sec. ----.42(b)(2)-3: When the primary purpose of a loan is to
finance an affordable housing project for low- or moderate-income
individuals, but, for example, only 40 percent of the units in question
will actually be occupied by individuals or families with low or
moderate incomes, should the entire loan amount be reported as a
community development loan?
A3.[rtrif]It depends.[ltrif] As long as the primary purpose of the
loan is a community development purpose [rtrif]as described in Q&A
Sec. ----.12 (h)-8[ltrif], the full amount of the institution's loan
should be included in its reporting of aggregate amounts of community
development lending. [However][rtrif]Even though the entire amount of
the loan is reported[ltrif], as noted in Q&A Sec. ----.22(b)(4)-1,
examiners may make qualitative distinctions among community development
loans on the basis of the extent to which the loan advances the
community development purpose.
[rtrif]In addition, if an institution that reports CRA data elects
to request consideration for loans that provide mixed-income housing
where only a portion of the loan has community development as its
primary purpose, such as in connection with a development that has a
mixed-income housing component or an affordable housing set-aside
required by federal, state, or local government, the institution must
report only the pro rata dollar amount of the portion of the loan that
provides affordable housing to low- or moderate-income individuals. See
Q&A Sec. ----.12(h)-8 for a discussion of ``primary purpose'' of
community development describing the distinction between the types of
loans that would be reported in full and those for which only the pro
rata amount would be reported.[ltrif]
Finally, as previously discussed, if the proposed revision to Q&A
Sec. ----.12(h)-8 is adopted as final, Q&A Sec. ----.22(a)(2)-4,
which provides examples of ``other loan data,'' would be revised to
delete ``loans that do not have a primary purpose of community
development, but where a certain amount or percentage of units is set
aside for affordable housing.''
Solicitation of Comments Regarding the Use