Interagency Q&A .21(b)(5) – 1: Can an institution’s assigned rating be adversely affected by poor past performance?

Compliance > Regulation BB - CRA
Q:  § __.21(b)(5) – 1: Can an institution’s assigned rating be adversely affected by poor past performance?
 
A:  Yes.  The Agencies will consider an institution’s past performance in its overall evaluation.  For example, an institution that received a rating of “needs to improve” in the past may receive a rating of “substantial noncompliance” if its performance has not improved.
 
 
 
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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