Interagency Q&A .26 – 1: When evaluating a small or int. small institution, will examiners consider, certain loans purchased by affiliates, qualified investments made by affiliates, or community development services provided by affiliates?

Compliance > Regulation BB - CRA
Q:  .26 – 1: When evaluating a small or intermediate small institution’s performance, will examiners consider, at the institution’s request, retail and community development loans originated or purchased by affiliates, qualified investments made by affiliates, or community development services provided by affiliates?
 
A:  Yes.  However, a small institution that elects to have examiners consider affiliate activities must maintain sufficient information that the examiners may evaluate these activities under the appropriate performance criteria and ensure that the activities are not claimed by another institution.  The constraints applicable to affiliate activities claimed by large institutions also apply to small and intermediate small institutions.  See Q&As addressing 12 CFR __.22(c)(2) and related guidance provided to large institutions regarding affiliate activities.  Examiners will not include affiliate lending in calculating the percentage of loans and, as appropriate, other lending-related activities located in an institution’s assessment area(s).
 
 
 
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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