SARC- 95-04 (October 4, 1995)

The Supervision Appeals Review Committee (“Committee”) of the Federal Deposit Insurance Corporation (“FDIC”), on September 22, 1995, considered your appeal of the Compliance and Community Reinvestment Act (“CRA”) ratings issued to [Bank] (“Bank”), pursuant to the Compliance Examination Report (“Report”) as of February 27, 1995.

The Committee concluded that the Compliance rating was appropriate given the violations cited, including the repetitive nature of several of the cited violations.  The Committee noted that the bank appeared to have taken appropriate corrective actions to address the violations cited; however, the basis for the rating was correct at the time the examination was conducted.  This determination is considered a final supervisory decision by the FDIC.

The Committee did not reach a conclusion on the CRA rating, however, since some of the material contained in the work papers and census information available to the examiner at the time of the examination, that might substantiate the examiner’s conclusions, had not been provided to the Bank.  Accordingly, the Committee directed staff to provide the information to the bank for its comments about the material before the Committee made a final determination on the substance of the appeal.  In order to permit this process to occur, the Bank must authorize an extension of the time period for the Committee to reach a decision.  It is our understanding that your Chairman has verbally agreed to such an extension.  When the Bank’s response is received, staff will bring the case back to the Committee for its further review and determination regarding the appeal of the CRA rating.

By direction of the Supervision Appeals Review Committee of the Federal Deposit Insurance Corporation.