Appeals of Material Supervisory Determinations: Guidelines
(December 6, 1996)
The Supervision Appeals Review Committee (Committee) of the
Federal Deposit Insurance Corporation (FDIC), on November 18, 1996,
considered your appeal of the Community Reinvestment Act (CRA) rating
issued to [Bank] (Bank), pursuant to the Community Reinvestment Act
Performance Evaluation (PE) as of May 1, 1996.
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 FDIC. The
Committee reached its determination after due consideration of the
information presented by the Bank and by the examiner in the PE.
An institutions capacity to meet
identified credit needs is influenced by several factors, including its
financial condition and size, resource constraints, legal impediments, etc.
that could affect the demand and supply of credit. Also, under the new CRA
an institutions performance is judged in the context of information about
the institution, its community, its competitors and its peers. In reaching
its determination, the Committee noted that credit needs for agricultural
and real estate loans had been identified within the Banks assessment
area. No material submitted with the Banks appeal provided any documented
support that the Bank is unable to meet any identified credit needs. The
Bank has the capacity and ability to address these needs both through its
strong financial condition and the loan products and services presently
The Committee was encouraged, however,
to learn that the Bank has begun to take affirmative actions to increase its
lending performance while maintaining safe and sound credit standards. The
Bank is encouraged to continue those efforts. The Bank is also encouraged
to contact the FDICs Community Affairs Officer at its Kansas City Regional
Office, Ms. Deanna Caldwell, (816) 234-8151, for any special assistance that
may be needed to improve its lending performance.
By direction of the Supervision Appeals
Review Committee of the Federal Deposit Insurance Corporation.