Interagency Q&A .21(b)(5) – 2: How will examiners consider the performance of similarly situated lenders?

Compliance > Regulation BB - CRA
Q:  § __.21(b)(5) – 2: How will examiners consider the performance of similarly situated lenders?
 
A:  The performance context section of the regulation permits the performance of similarly situated lenders to be considered, for example, as one of a number of considerations in evaluating the geographic distribution of an institution’s loans to low-, moderate-, middle-, and upper-income geographies.  This analysis, as well as other analyses, may be used, for example, where groups of contiguous geographies within an institution’s assessment area(s) exhibit abnormally low penetration.  In this regard, the performance of similarly situated lenders may be analyzed if such an analysis would provide accurate insight into the institution’s lack of performance in those areas.  The regulation does not require the use of a specific type of analysis under these circumstances.  Moreover, no ratio developed from any type of analysis is linked to any lending test rating.
 
 
 
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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