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Appeals of Material Supervisory Determinations: Guidelines & Decisions

SARC-96-07 (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 Bank’s 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 its market.

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.