Appeals of Material Supervisory Determinations: Guidelines
(June 26, 1996)
The Supervisory Appeals Review
Committee (Committee) of the Federal Deposit Insurance Corporation
(FDIC), on June 21, 1996, considered your appeal of the Community
Reinvestment Act (CRA) rating issued to [Bank] (Bank), pursuant to the
Compliance Examination Report (Report) as of August 18, 1995.
The Committee, after a review of the material
submitted with the appeal, has concluded that the CRA rating should be
affirmed. This decision is considered a final supervisory determination by
The Committee reached its
determination after due consideration of the information presented by the
Bank and the material contained in the examination report. While it was
evident to the Committee that the Banks overall lending performance was
satisfactory, the Committee concluded that the performance was insufficient
to warrant an increase in the overall rating to an Outstanding.
Considered in reaching this conclusion was the Banks conservative lending
policy and restrictive lending terms that contribute to a relative low loan
volume within the community.
The committee notes that
the appeal was submitted well after the time frames contained in the FDICs
Guidelines for Appeals of Material Supervisory Determinations
(Guidelines). It is further noted that avenues of communication through
the regional office were not pursued by the Bank with regard to the appeal
and the related report of examination. The Committee wanted to share its
view that the examination and appeals process work more effectively if there
is open communication between the bank and the regional office and issues
are presented and addressed in a timely manner at that level.
By direction of the
Supervisory Appeals Review Committee of the Federal Deposit Insurance