Appeals of Material Supervisory Determinations: Guidelines
(October 18, 1995)
In accordance with the FDIC’s
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
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.