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COMMUNITY REINVESTMENT ACT (CRA) DATA COLLECTION, REPORTING, MAINTENANCE AND EXAMINATION MATRIX (includes 7/2005 joint final rules)

Coverage

Banks, Savings Associations and Thrifts with assets of $1 Billion or more.

Scope

Required Data Elements · Unique Number or Alphanumeric Symbol for identification · Loan amount at origination · Loan location · Revenue indication Required Data Elements · Unique Number or Alphanumeric Symbol for identification · Loan amount at origination · Loan location · Gross annual income Required Data Elements · Aggregate number and amount

Performance Context Small Business and Small Farm Loans

CRA RELIEF Features

· · The Application / Loan Information Screen encompasses required data fields, with drop down menus for selecting appropriate data. Built-in data field edits ensure only valid data will be collected and reported.

DATA COLLECTION REQUIREMENTS

Consumer Loans (Optional)

See Above

Community Development/ Consortium/Third Party

·

·

Community Development loans are retained on a per record basis. The program aggregates each loan and reports the total number and dollar amount in the submission. Community Development totals by number and dollar performance are presented in several reports. Institution Register Summary and Data Listing Reports are two.

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

Blue denotes new revision. Revised July 22, 2005

1

Coverage

Banks, Savings Associations and Thrifts with assets of $1 Billion or more.

Scope

Performance Context

CRA RELIEF Features

· · · · · · ·

REPORTED DATA REQUIREMENTS

Annually by March 1st

Required Data · Loan geography of originations and purchases · Aggregate number and amount at origination o $100,000 or less o $100,000 < $250,000 o > $250,000 · Revenue indicator of $1,000,000 or less Required Data · Aggregate number and amount of originations and purchased Required Data · Loan geography of originations and purchases · Aggregate number and amount at origination o $100,000 or less o $100,000 < $250,000 o > $250,000 · Revenue indicator of $1,000,000 or less · Comply with requirement for Community Development Loans as appropriate Required Data · A list of the geographies · Provided for each

Small Business and Small Farm Loans

Submission file is attached to an automated email that has been programmed with all required information based on user-identified regulator. Submission file meets regulatory encryption standards. Retention of submission saved in the program. Instant Geocoder product has been integrated into the program for geocoding records. Instant Geocoder has proven track record for compliance with data integrity requirements. Program aggregates loans and automatically calculates reporting categories for each loan size category in the submission. Use the Institution Register Summary report to validate submission totals.

Community Development/ Consortium/Third Party (Optional Reporting) Affiliate Lending (Optional Reporting)

· · · ·

Program aggregates the number and dollar amount of loans for submission. Data Listing report can be used to validate submission totals. If opted to report, the program includes records in submission. Affiliate code indicators are added to the Data Listing reports for validating submission totals.

Assessment Area

· ·

The program automatically tallies the census tracts for each assessment area based on the user selections. The Assessment Area Summary and Detail reports can be used for validating delineation accuracy and detail.

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

Blue denotes new revision. Revised July 22, 2005

2

Exam Type

Banks, Savings Associations and Thrifts with assets less than $1 Billion.

Scope

Assessment Area Defined

Performance Context

· One or More MSA's OR Contiguous · Counties, Cities, Towns OR Contiguous · Whole Census Tracts or Block Numbering Areas · · · Demographic Analysis Economic Analysis Peer Comparison Analysis o o o o o UBPR UTPR Call Reports CRA Evaluations HMDA Data

Examiner Conclusions

· · ·

· · · · · · · · · ·

CRA RELIEF Reports for Examiner/Institution

See Assessment Area Section for Data Collection and Data Reported.

SMALL BANK EXAMINATION REQUIREMENTS Must include Main Office, Branches and Deposit-taking ATM's Must include Surrounding Geographies in which the Substantial Amount of Loans were Originated or Purchased Does not Arbitrarily Exclude Low or Moderate Income Areas

Number of Single-family Homes in AA Number of Multi-family Homes in AA Race Composition (All race categories) Number of Businesses Number of Farms Median-family Income by Geography Population by Income The Number of Other Institutions in Assessment Areas (Asset-size and Financial Strength) CRA Performance of Like-Institutions in AA HMDA Data for Institutions in AA

Lending Opportunities in Different Assessment Areas

·

·

The Assessment Area Summary Report gives you summary totals of MA, County, Census Tract and Tract Income categories for each assessment area delineated. The Assessment Area Detail Report provides a listing of all census tracts, branch/ATM/LPO locations broken out be MSA, then City.

Level of Lending Activities in Different Assessment Areas

·

· ·

·

The Number and Dollar volume of loans originated and purchase in AA The Percentage of loans originated and purchased in AA Analyze the distribution of loans in AA among different income geographies Analyze the number and dollars of loans to borrowers and business of different income and revenue levels

·

Analysis of whether a majority of loans were made in the Institutions AA by number and dollar Were the loans made in the AA distributed to borrowers of different income levels comparative to population census income data o Low/Mod vs Mid/Upper Were there geographies with Low or No performance Were there categories with Low or No penetration o Low/Mod vs Mid/Upper o Revenues < $1M o Secondary by Loan Size

·

· ·

These reports are used to develop and review your performance context for each assessment area. They present the total number of census tracts in each income category, with percentages for lending performance comparison. · You are able to analyze lending inside in comparison to outside your assessment area by using the Assessment Area Aggregate Loan Volume report: · Assessment Area Aggregate Loan Volume Report presents an institution's loan distribution performance by number, dollar and percentages of both. The report breaks-out census tracts by income category and loan type. · Institution Register Summary Report presents the total number and dollar of loans originated for each MSA broken out by loan type, revenue of <=$1M and loan size (<$100K, $100-$250K, >$250K).

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

Blue denotes new revision. Revised July 22, 2005

3

Exam Type

Banks, Savings Associations and Thrifts with assets less than $1 Billion.

Scope

Anomalies in the Reported HMDA Data in Different Assessment Areas

Performance Context

· Analyze the number and dollars of home mortgage loans in AA vs Outside AA Analyze the Percentage of home mortgage loans in AA vs Outside AA Analyze the distribution of HMDA loans among different geographies Sample a small percentage of HMDA loans to validate accuracy

Examiner Conclusions

· · Analysis of whether a majority of loans were made in the Institutions AA by number and dollar Were the loans made in the AA distributed to borrowers of different income levels comparative to population census income data o Low/Mod vs Mid/Upper o Were there geographies with Low or No performance

CRA RELIEF Reports for Examiner/Institution

·

Assessment Area Aggregate Loan Volume Report ­ Home Mortgage You are able to analyze lending inside in comparison to outside your assessment area by using the Assessment Area Aggregate Loan Volume report:

SMALL BANK EXAMINATION REQUIREMENTS

· · ·

INTERMEDIATE SMALL BANK EXAMINATION REQUIREMENTS

Banks with assets of at least $250 Million and less than $1 Billion.

Community Development Lending Community Development definition revised to include: · · Designated disaster areas; or Distressed or underserved nonmetropolitan middle-income geographies as designated by the Joint Agencies

·

Analyze the Number and Amount of Community Development Loans

·

Compare to opportunities for community development lending in AA

·

CRA RELIEF only allows purpose selections that are in Compliance with the regulatory definition: o Affordable housing for lowor moderate-income individuals o Community services targeted to low-or moderate-income individuals o Activities that promote economic development by financing small businesses or small farms o Activities that revitalize or stabilize low-or moderateincome geographies · CRA RELIEF provides three reports for analyzing performance: o Assessment Area Aggregate Loan Volume Report o Institution Register Summary Report o Community Development Data Listing Report These reports provide summaries of number and dollar performance with data detail and graphed percentages.

Blue denotes new revision. Revised July 22, 2005

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

4

Exam Type

Banks, Savings Associations and Thrifts with assets of $1 Billion or more.

Scope

Assessment Area Defined

Performance Context

· Same as Small Bank

Examiner Conclusions

· Same as Small Bank

CRA RELIEF Reports for Examiner/Institution

See Assessment Area Section in the Data Collection and Reporting Sections.

LARGE BANK EXAMINATION REQUIREMENTS

Lending Opportunities in Different Assessment Areas

·

Same as Small Bank

·

Same as Small Bank

·

Lending Inside and Outside Assessment Area

·

Analyze the Number and Dollar Volume, and Percentage of Each Loan Type in Each Geography Analyze the Number of Geographies Penetrated in Each Income Category compared to the Total Number of Geographies within the AA

· · · ·

Main focus on performance in each geographic category Emphasis place on geographies with Low or No lending activity Main focus on dispersion matching AA performance context Emphasis on high percentage disparities

·

The Assessment Area Summary Report gives you summary totals of MA, County, Census Tract and Tract Income categories for each assessment area delineated. · The Assessment Area Detail Report provides a listing of all census tracts, branch/ATM/LPO locations broken out be MSA, then City. These reports are used to develop and review your performance context for each assessment area. They present the total number of census tracts in each income category, with percentages for lending performance comparison. · You are able to analyze lending inside in comparison to outside your assessment area by using the following reports: o Assessment Area Aggregate Loan Volume Report o Assessment Area Summary Report o Assessment Area Detail Report The Assessment Area Aggregate Loan Volume Report presents performance by numbers, dollars and percentages, with graphs. The Assessment Area Reports give the details of loans in your assessment area, along with dispersion percentages.

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

Blue denotes new revision. Revised July 22, 2005

5

Exam Type

Banks, Savings Associations and Thrifts with assets of $1 Billion or more.

Scope

Geographic Distribution of Loans Inside and Outside Assessment Area

Performance Context

· Analyze the Number of Geographies Penetrated in Each Income Category compared to the Total Number of Geographies within the AA Analyze the Number and Dollar Volume of Home Mortgage Loans in Each Geography compared to the Number of Homes in Assessment Area Analyze the Number and Dollar Volume of Small Business and Farm Loans in Each Geography Analyze the Number and Dollar Volume, and Percentage of Total Home Mortgage Loans in the Different Income Categories Analyze the Percentage of Total Home Mortgage Loans within AA Compared to the Percentage of the Population in Each Income Category Analysis of Consumer Loans are optional Analyze the Number and Dollar Volume of Small Loans to Businesses or Farms by Loan Size Analyze the Number and Dollar Volume of Small Business and Farm Loans that had Annual Revenue of Less the $1MM Compared to Total Number Loans to Small Businesses and Farms

Examiner Conclusions

· · Main focus on dispersion matching AA performance context Emphasis on high percentage disparities

CRA RELIEF Reports for Examiner/Institution

· You are able to analyze lending inside in comparison to outside your assessment area by using the Assessment Area Aggregate Loan Volume report. Assessment Area Aggregate Loan Volume Report presents an institution's loan distribution performance by number, dollar and percentages of both. The report breaks-out census tracts by income category and loan type.

LARGE BANK EXAMINATION REQUIREMENTS

·

· · · · · · Main focus on dispersion matching AA housing performance context (Single-family and Multi-family) Emphasis high disparities

·

Distribution of Lending by Borrower Characteristics within Assessment Area

·

Main focus on dispersion matching AA performance context Emphasis on high percentage disparities Main focus on performance with Low/Mod vs Mid/Upper

·

·

·

Assessment Area Aggregate Loan Volume Report ­ Home Mortgage Loans. You are able to analyze lending inside in comparison to outside your assessment area by using the Assessment Area Aggregate Loan Volume report. You are able to analyze lending inside in comparison to outside your assessment area by using the Assessment Area Aggregate Loan Volume report.

Main focus on performance with Low/Mod vs Mid/Upper

·

· ·

·

Main focus on performance with Low/Mod vs Mid/Upper

·

· · · ·

Main focus on performance with Low/Mod vs Mid/Upper Emphasis placed on high percentage disparities Main focus on Low percentage performance Compare performance to lending outside AA

·

Assessment Area Aggregate Loan Volume Report presents an institution's loan distribution performance by number, dollar and percentages of both. The report breaks-out census tracts by income category and loan type.

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

Blue denotes new revision. Revised July 22, 2005

6

Exam Type

Banks, Savings Associations and Thrifts with assets of $1 Billion or more.

Scope

Community Development Lending Community Development definition revised to include: · · Designated disaster areas; or Distressed or underserved nonmetropolitan middle-income geographies as designated by the Joint Agencies

Performance Context

· Analyze the Number and Amount of Community Development Loans

Examiner Conclusions

· Compare to opportunities for community development lending in AA

CRA RELIEF Reports for Examiner/Institution

· CRA RELIEF only allows purpose selections that are in Compliance with the regulatory definition: o Affordable housing for lowor moderate-income individuals o Community services targeted to low-or moderate-income individuals o Activities that promote economic development by financing small businesses or small farms o Activities that revitalize or stabilize low-or moderateincome geographies · CRA RELIEF provides three reports for analyzing performance: o Assessment Area Aggregate Loan Volume Report o Institution Register Summary Report o Community Development Data Listing Report These reports provide summaries of number and dollar performance with data detail and graphed percentages.

LARGE BANK EXAMINATION REQUIREMENTS

OTS Community Development definition revised to include: · Rural areas

SOURCE: SMALL AND LARGE INSTITUTION EXAMINATION PROCEDURES, FFIEC PUBLISHED APRIL, 1997 OTS 12 CFR, PART 563e, CRA FINAL RULE, PUBLISHED IN THE FEDERAL REGISTER , MARCH, 2005 CRA JOINT FINAL RULE, OCC 12 CFR PART 25, FRB 12 CFR PART 228, FDIC 12 CFR PART 345, PUBLISHED JULY, 2005

Blue denotes new revision. Revised July 22, 2005

7

Information

Exam Type

7 pages

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