Interagency Q&A .21(b)(4) – 1: Will examiners consider factors outside of an institution’s control that prevent it from engaging in certain activities?

Compliance > Regulation BB - CRA
Q:  § __.21(b)(4) – 1: Will examiners consider factors outside of an institution’s control that prevent it from engaging in certain activities?
 
A:  Yes.  Examiners will take into account statutory and supervisory limitations on an institution’s ability to engage in any lending, investment, and service activities.  For example, a savings association that has made few or no qualified investments due to its limited investment authority may still receive a low satisfactory rating under the investment test if it has a strong lending record.
 
 
 
This Interagency Q&A, and others, was released in July 2016.  The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately.  They may be found here:  http://www.ffiec.gov/cra/qnadoc.htm
 

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