Interagency Q&A APPENDIX A to Part __ – 1: Must an institution’s performance fit each aspect of a particular rating profile in order to receive that rating?

Compliance > Regulation BB - CRA
Q APPENDIX A to Part __ – 1: Must an institution’s performance fit each aspect of a particular rating profile in order to receive that rating?
 
A:  No.  Exceptionally strong performance in some aspects of a particular rating profile may compensate for weak performance in others.  For example, a retail institution other than an intermediate small institution that uses non-branch delivery systems to obtain deposits and to deliver loans may have almost all of its loans outside the institution’s assessment area(s).  Assume that an examiner, after consideration of performance context and other applicable regulatory criteria, concludes that the institution has weak performance under the lending criteria applicable to lending activity, geographic distribution, and borrower characteristics within the assessment area(s).  The institution may compensate for such weak performance by exceptionally strong performance in community development lending in its assessment area(s) or a broader statewide or regional area that includes its 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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