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Appeals of Material Supervisory Determinations: Guidelines & Decisions

SARC-96-04 (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 FDIC.

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 Bank’s 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 Bank’s 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 FDIC’s 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 Corporation.