The Federal Deposit Insurance Corporation (FDIC) has developed the attached
guidelines for financial institutions choosing to have their Community
Reinvestment Act (CRA) performance evaluated under the strategic plan
option. The attachment supplements existing guidance for preparing and
submitting a strategic plan to the FDIC for approval.
Under the revised CRA regulations, a financial institution may select the
strategic plan approach. This method provides the institution an
opportunity to tailor its CRA objectives to help meet the credit needs
of its community consistent with its business strategy and operational
focus. The FDIC previously provided guidance about the information to be
included in a strategic plan. However, questions and areas of concern
remained, particularly about developing measurable goals and appropriate
performance information. The FDIC's strategic plan review process also
The strategic plan's required contents and the FDIC's criteria for
evaluating a strategic plan are included in the FDIC's CRA regulations,
12 C.F.R. sec. 345.27. The strategic plan approach offers considerable
flexibility to institutions in choosing how to measure their CRA
performance. As a result, not all of the factors described in these
guidelines will apply to each institution.
The attached guidelines address various issues that have arisen in the
FDIC's review of strategic plan submissions since the option became
available in January 1996. The FDIC believes that the lessons learned
during these earlier reviews may assist institutions that are considering
this alternative evaluation approach to demonstrating CRA performance.
One section in the guidelines identifies specific resources from which
institutions may obtain demographic, economic and related data to prepare
their plans. The information sources include the FDIC and selected agency
The FDIC recognizes that developing a viable strategic plan is
labor-intensive and costly. We commit to this promise: if a financial
institution expends the effort to meet the criteria outlined in this
guide and in other official information sources, the FDIC will respond
expeditiously with an affirmative decision.
FDIC staff members are available to help institutions develop their
strategic plan submissions. For further information, please contact
the appropriate Division of Compliance and Consumer Affairs regional
office on the attached list.
Distribution: FDIC-Supervised Banks (Commercial and Savings)
NOTE: Paper copies of FDIC financial
institution letters may be obtained through the FDIC's Public
Information Center, 801 17th Street, N.W., Room 100, Washington,
D.C. 20434 (800-276-6003 or (703) 562-2200).