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Inactive Financial Institution Letters


July 18, 2000

SUBJECT: Revised, New and Proposed Interagency Questions
and Answers Regarding Community Reinvestment

The Federal Financial Institutions Examination Council (FFIEC) published the attached "Interagency Questions and Answers Regarding Community Reinvestment" (Q&As) on April 28, 2000, in the Federal Register. The Q&As, except as noted below, were effective upon publication. The document also is available on the FFIEC's Web site at:

These interagency Q&As have been prepared by the staff of the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision for agency personnel, financial institutions and the public. This version supplements and amends the Q&As published by the FFIEC on May 3, 1999. As with the prior version of the Q&As, this document incorporates all previously issued questions and answers that are still in effect.

The Q&As include two of the questions and answers proposed in May 1999, along with a conforming change to another existing Q&A. The two questions address:

  1. whether an institution may receive consideration under the investment test for mortgage-backed securities backed by loans originated or purchased by the same institution, and

  2. whether renewals and refinancings of small business and small farm loans should be collected and reported.

To minimize the burden placed on institutions, the latter revised question and answer will become effective for Community Reinvestment Act (CRA) data collected in 2001 and reported in 2002. Institutions should, therefore, begin planning now to ensure timely implementation of necessary changes to forms and procedures. There are also slight revisions to four existing Q&As, and a new Q&A has been added. Finally, a keyword index has been substituted for the table of contents used in earlier versions of the Q&As.

The third Q&A originally published on May 3, 1999, has been reissued for comment, along with a conforming amendment to an existing Q&A. The reissued and revised Q&A addresses whether there must be some immediate or direct benefit to the institution's assessment area(s) to satisfy the regulation's requirements 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 assessment area. In addition, a new Q&A is proposed to address what is meant by the term "regional area."

We invite public comment on the proposed questions and answers, any of the new and revised questions and answers, and any other community reinvestment issues not addressed in the document.

For more information, please contact Robert W. Mooney, Assistant Director for CRA and Fair Lending Policy in the FDIC's Division of Compliance and Consumer Affairs (DCA), on (202) 942-3378 or A. Ann Johnson, Counsel in the FDIC's Legal Division, on (202) 898-3573. You also may contact your DCA Regional Office on the attached list.

Stephen M. Cross

Attachments:  (1) Regional Office Listing for FDIC's Division of Compliance and Consumer Affairs;
(2) Federal Register, April 28, 2000, Vol. 65, No. 83, pages 25088-25120
HTML or PDF (330 KB File - PDF Help or Hard Copy

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, NW, Room 100, Washington, DC 20434 (800-276-6003 or (703) 562-2200).

Last Updated 07/18/2000

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