Interagency Q&A .26(c)(3) – 1: What will examiners consider when evaluating the provision of community development services by an intermediate small institution?

Compliance > Regulation BB - CRA
Q:  § __.26(c)(3) – 1: What will examiners consider when evaluating the provision of community development services by an intermediate small institution?
 
A:  In addition to the examples listed in Q&A § __.12(i) – 3, examiners will consider retail banking services as community development services if they provide benefit to low- or moderate-income individuals.  Examples include: 
 
•  low-cost deposit accounts; 
•  electronic benefit transfer accounts and point of sale terminal systems;
•  individual development accounts; 
•  free or low-cost government, payroll, or other check cashing services; and
•  reasonably priced international remittance services. 
 
In addition, providing services to low- and moderate-income individuals through branches and other facilities located in low- and moderate-income, designated disaster, or distressed or underserved nonmetropolitan middle-income areas is considered.  Generally, the presence of branches located in low- and moderate-income geographies will help to demonstrate the availability of banking services to low- and moderate-income individuals.
 
 
 
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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