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 Compliance
Examination Report (Report) as of April 15, 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, the material contained in the examination
work papers and other material available to the examiner.
In reaching its determination, the
Committee noted that the overall demographics of the Banks market area and
the level of competition within the Pensacola market area indicated an
economy that has been expanding and thereby offering opportunities for
credit expansion consistent with safe and sound banking practices.
The Committee concluded that the overall
lending performance of the Bank remains in need of improvement given the
strong financial condition of the Bank and the economic conditions within
The Committee was encouraged, however,
to learn that the Bank is taking affirmative actions to increase its lending
performance while maintaining safe and sound credit standards. The
Committee encourages the board of directors to continue those efforts and it
also encourages the Bank to contact the Community Affairs Officer at its
Atlanta Regional Office, Mr. James Pilkington, (404) 817-2515, for any
special assistance the board of directors believes may be needed to improve
its lending performance.
By direction of the Supervision Appeals
Review Committee of the Federal Deposit Insurance Corporation.