Appeals of Material Supervisory Determinations: Guidelines & Decisions
SARC-95-05 (October 18, 1995)
In accordance with the FDIC’s Guidelines for Appealing Supervisory Determinations, I have reviewed your appeal, on behalf of [Bank] (“Bank”), of the Community Reinvestment Act (CRA) Rating assigned to… pursuant to the FDIC’s Compliance and CRA Examination Report as of February 27, 1995. Based on my staff’s analysis of the examination findings and conclusions, the examination workpapers, and data submitted by you and Bank, I have decided to grant the request for a “Satisfactory” CRA Composite Rating.
Our records and examination schedule will be adjusted to reflect the “Satisfactory” rating, instead of “Needs to Improve.” Additionally, my staff will prepare a revised CRA Performance Evaluation for Bank public files. Bank can expect receipt in thirty (30) days. Until Bank receives the revised Performance Evaluation, this letter should be placed in the bank’s public files.
Although I have decided to approve the appeal, I encourage management’s continued focus and marketing efforts on the Northside area of its delineated community, and all other low-to-moderate-income areas within the delineated community. The CRA specifically emphasizes the need for financial institutions to meet the credit needs of its entire community, including low-to moderate-income neighborhoods. A financial institution’s CRA efforts should not be limited to the immediate areas surrounding its branches.
Management is also encouraged to continually monitor the success of its marketing efforts and make adjustments accordingly. Adjustments should be based on the volume of lending, information received from community contacts, and recommendations made in reports of examination. We view favorably the products Bank has already designed for low-to-moderate-income areas, and encourage Bank’s management and directorate to monitor the effect of these products.
We appreciate Bank’s assistance and submission of additional information during our appeal process. If we can be of further assistance, please don’t hesitate to contact me.