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Examination Procedures- Overview

The Board of Governors of the Federal Reserve System, the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision approved examination procedures to implement the revised Community Reinvestment Act (CRA) regulations that were published in the Federal Register on May 4, 1995. All of the procedures reflect the intent of the regulation to establish performance-based CRA examinations that are complete and accurate but, to the maximum extent possible, mitigate the compliance burden for institutions.

The procedures are periodically revised by the agencies based on the interagency review.

In August 2005, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation made significant changes to their CRA Regulations. To address the changes in the regulations, the three agencies also revised their examination procedures for all examination types. On July 1, 2007, the Office of Thrift Supervision adopted a CRA final regulation mirroring the regulations of the other agencies. Consequently, effective July 1, 2007, all four agencies are using the same CRA regulations and related examination procedures.


Intermediate Small Institution Examination Procedures

On July 19, 2005, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation revised their Community Reinvestment Act regulations. On July 1, 2007, the Office of Thrift Supervision revised their CRA regulation, which is now consistent with the regulations that the other agencies have been using since September 1, 2005. Among the revisions to the agencies regulations is a new test, the community development test, for small banks with total assets of at least $250 million as of December 31 of both of the prior two calendar years and less than $1 billion as of December 31 of either of the prior two calendar years (asset thresholds are adjusted annually). These banks will be examined under the existing small bank lending test and the community development test for intermediate small banks. The agencies have adopted joint interagency examination procedures for intermediate small banks.

Note, the CRA regulation continues to allow small institutions, including intermediate small institutions, to opt for examination as a large bank under the lending, investment, and service tests. These recent revisions did not change that option.

Intermediate small institutions are not required to collect and report CRA loan data for small business, small farm, and community development loans. Banks may retain data collected at their option, for internal tracking, analysis, or planning purposes.

To evaluate the distribution of loans, examiners will review loan files, bank reports, or any other information or analyses banks may provide. In addition, to evaluate community development loans, qualified investments, and community development services, examiners will review any information banks may provide, including the results of any assessment of community development needs and opportunities; and performance context information obtained by examiners from community, government, civic, and other sources.

Refer to the regulations for information on the other changes.

Availability of Material

Copies of the procedures, corresponding sample public performance evaluations, and background introductory material for examiners are available.