Interagency Q&A .41(e)(3) – 1: How will examiners determine whether an institution has arbitrarily excluded low- or moderate-income geographies?

Compliance > Regulation BB - CRA
Q:  § __.41(e)(3) – 1: How will examiners determine whether an institution has arbitrarily excluded low- or moderate-income geographies?
 
A:  Examiners will make this determination on a case-by-case basis after considering the facts relevant to the institution’s assessment area delineation.  Information that examiners will consider may include
 
•  income levels in the institution’s assessment area(s) and surrounding geographies;
•  locations of branches and deposit-taking ATMs;
•  loan distribution in the institution’s assessment area(s) and surrounding geographies;
•  the institution’s size;
•  the institution’s financial condition; and
•  the business strategy, corporate structure, and product offerings of the institution.
 
 
 
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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