Spoiler Alert!!! Some movies have such a twist, you walk out of the theater in total shock! 2 “Fight Club” “The Others” “The Sixth Sense”
Spoiler Alert!!! I’m guessing that would not be such a good feeling as you walk out of an exit meeting with Examiners! 3
Spoiler Alert Flip the Script!! Be the Director……..Know “Your Story” before they do. Centrax holds the ending….you just have to know where to look. 4
Spoiler Alert The CRA Performance Evaluation is your story. The report is broken down into sections, that when combined, give a complete picture of the institutions performance. The main sections of the CRA PE are: – Overview – Demographics – Lending Performance Small Business Small Farm HMDA Lending Consumer Lending (optional) – Services – Investments 5
Demographics Centrax has a variety of Demographic Reports for you to pull information from. The Demographic Reports can be found under Discovery>Research>Reports>Demographic Reports. 7
Demographics The Demographic Summary Report is a good place to start. It provides an overview of the area on one page. Discovery>Research>Reports>Demographic Reports>Summary Report. 8
Demographics The Report Setup page allows you to choose a Geographic Area. – State – MSA –County – Tract Group If Tract Group is selected, you can then select the area for review. 9
Demographics 10 Population Data Housing Data Geographic Distribution Data by Tract Income Level Other Data – Households below Poverty Level Median Family Income
Demographics The headers and footers provide key information about the data provided. What File the report was run on. What Geographic area was used. If Filters were used. What demographic year was used. 11
Demographics The Demographic by Tract Category Report goes into a bit more detail. Gives demographic information within each tract level on a four page report. Discovery>Research>Reports>Demographic Reports>Assessment Area Summaries> Demographics by Tract Category. 12
Demographics The Report Setup page allows you to choose a Geographic Area. – State – MSA –County – Tract Group If Tract Group is selected, you can then select the area for review. 13
Demographics This report shows more detailed information within each tract category. The Total column gives you the total within the geographic area selected. 14
Demographics The second page provides information on Household and Housing Data. Families Below the Poverty Level comes into play when adding context to Borrower Distribution. 15
Demographics Page 3 and 4 go on to provide information by Census Tract Minority Level. 16
Spoiler Alert 17 Production Reports 2 CRA Officer 3A - Right Performance Evaluation
Production Reports The Exam Tables only show loans Inside of the selected assessment area. The Reportable Loan Summary Report will show activity both inside and outside of the assessment area. The Reportable Loan Summary Report can be found under Discovery>Research>Reports>Distribution/Summary Reports> Reportable Loan Summary. 18
Production Reports The report setup is very simple for this report. Select your Assessment Area from the drop down box, click Ok. ……But first, lets talk about Assessment Areas and how if effects some of these reports. 19
Production Reports In Centrax the Assessment Area and Tract Group function are combined. The difference between the two, the Assessment Areas are reported on your CRA LR. From the main menu, select Setup>Tract Groups/AAs. 20 AA’s are determined by this box. If you have multiple AAs, you could create a Combined AA and not check the box.
Production Reports For the Reportable Loan Summary we will run using the 2012 Combined AA previously setup. Select Ok 21
Production Reports This report gives us the % of loans, originated & purchased only, inside and outside our selected Combined AAs. 22
Production Reports The Activity Outside Assessment Area report will show you specifically where the loans outside of your AA are being made. Discovery>Research>Reports>HMDA Reports> Activity Outside Assessment Area. 23 Yes, it will work for CRA data!
Production Reports Select your Combined Assessment Area. Select a geography to analyze that is outside of your AA. If does not have to be larger even though the label says it does. 24
Production Reports The Activity Outside Assessment Area report will show you specifically where the loans outside of your AA are being made. Discovery>Research>Reports>HMDA Reports> Activity Outside Assessment Area. 25
Production Reports Now let’s look at our activity in our Assessment Area. The Tract Penetration Summary Report will provide that information. Discovery>Research>Reports>CRA Reports> Tract Penetration Summary. 26
Production Reports This report has a detail section and a summary. You have the option to run just the summary by checking the box. Select your geographic area, click Ok. 27
Production Reports The summary report tells us we made 61 loans within 24 Low Income Tracts, out of a possible 46 Low Income Tracts. Leaving 22 Low Income Tracts that we did not penetrate. 28
Production Reports The detail report lists all tracts in the geography selected. 29 Even if you did not make a loan in that tract.
Production Reports Since we do not have to make loans in every tract in our Assessment Area, we want to be able to explain any gaps in our lending. The Low Activity Report will provide us that information. Discovery>Research>Reports>CRA Reports> Low Activity Tract Profile. 30
Production Reports Set the Include Tracts by option to Number of Loans less than 1. This will give us all the tracts in the selected Geographic Area that had zero loans. 31 If you would like to limit this report to only unpenetrated low- and moderate-income tracts, check the Include Only low/mod Tracts option.
Production Reports The report can also be specific to a category of loans but setting a filter prior to running the report. 32
Spoiler Alert The Public Evaluation (PE) contain text where the examiner explains their evaluation of your lending practices along with a table showing the data they used to reach their conclusions. With the Exam Tables in Centrax, you can replicate what the examiner will be looking at. 34
Spoiler Alert The text looks similar to this. Your goal is to fill in the blanks. 35
Spoiler Alert From the main menu, select Discovery> Exam Tables. 36
Spoiler Alert To run the reports from a file or files other than the active file, click Other Files. To select files, double click or highlight and use arrows. If you use Other Files, you must select the active file in order for it to be included. 37
Spoiler Alert Select the Assessment Areas you want to work with. Select the Tables you want to run. If you are working with multiple years of data, you can set the dates and choose to run by year. 38
Spoiler Alert The Demographic Information Report gives an overview for the Assessment Area. The data comes from the census with the exception of the Business/Farm Demographics and anything with a HUD in the label. 39 You will have a page for each AA selected.
Spoiler Alert Table 1 – Lending Volume is a 3 page report covering all loan types. If you had deposit information in your file, you could compare lending to deposits. The % should be reasonably close. 40 The examiner will use these %’s to determine the weight of each AA.
Spoiler Alert Table 2 – Geographic Distribution of Home Purchase Loans. You will use this Table to fill in the text previously discussed. CRA focuses on Low- and Moderate-Income Geographies and Borrowers. So that is where our focus will be. 41
Spoiler Alert 1 – The Demographic statistic. This will change depending on the report you are working with. 2 – The percent of loans in this income segment from the active data file. 3 – Below the line – percent of total loans made by all lenders to this income segment in the most recent public data available. The footnotes will indicate year. 4 - Above the line – Your percent of the total loans made by all lenders to this income segment in the most recent public data available. 42 1221 3 4 5 6 7
Spoiler Alert 5 - Your rank in the market based on the Overall Market Share. 6 - Number of total lenders that made Home Purchase loans (depending on the table you are looking at). 7 –Your percent of the total loans made by all lenders in the geography in the most recent public data available. 43 1221 3 4 5 67
Spoiler Alert Within the Pittsburgh AA, the Bank made 1.11% (1) of loans within Low-Income Geographies. This is below the 2.13% (2) of Owner Occupied Housing Units. 44
Spoiler Alert Now we can start putting some of our numbers into context. “During the review period, the bank originated 359 home purchase loans totaling $____ within the assessment area. The bank originated 1.11% (1) of these loans in low-income areas compared to 2.13% (2) of owner-occupied housing units located in low-income census tracts. Additionally, the bank originated 16.43% (1) of these loans in moderate-income areas as compared to 19.20% (2) of owner-occupied housing units in moderate-income census tract.” 45
Spoiler Alert To cover the right side of the Table the context looks similar to this. “In 2011, the bank ranked 16 th (5) out of 342 (6) lenders for home purchase loans within its assessment area. The bank’s overall market share was 1.23% (7). Within low-income tracts the bank had a market share of 1.27% (4) compared to the aggregate lending of 1.08% (3). Within moderate-income tracts the bank’s market share was 1.72 (4) compared to the aggregate lending of 11.79% (3).” 46
Spoiler Alert Now, let’s find that last number. “During the review period, the bank originated 359 home purchase loans totaling $____ within the assessment area.” The Summary Report can help us find the numbers and dollars that make up the percentages. From the main menu select, Discovery>Research>Reports>Distribution/Summary Reports>Summary Report. 47
Spoiler Alert A filter will need to be set to limit the report to the factors making up the Exam Table 2. Our filter should reflect originated and purchased action, HMDA Purpose of Home Purchase, and we want to limit the Tract Group to our Pittsburgh AA. 48 Notice our count matches the Total Loans from Table 2.
Spoiler Alert The Report Setup should include Tract Income Level for the Field Selection. We want to include Purchased Loans. And the Balance Field should be HMDA. 49
Spoiler Alert We now have the total dollar amount of Home Purchase loans, originated and purchased, for the Pittsburgh Assessment Area. 50
Spoiler Alert Tables 3-5 are read the same way, they just cover Home Improvement, Refinance, and Multifamily loans. 51
Spoiler Alert Tables 6 & 7 cover Small Business and Small Farm and change slightly. They are set up exactly the same way, but the comparator changes to % of Businesses (or Small Farms) within the tract. 52 1 122
Spoiler Alert Our write up for Small Business/Small Farm would look similar to this. “During the review period, the bank originated 1,363 Small Business loans totaling $____ within the assessment area. The bank originated 1.32% (1) of these loans in low-income tracts compared to 7.37% (2) of Small Businesses located in low-income census tracts. Additionally, the bank originated 17.61% (1) of these loans in moderate-income areas as compared to 19.21% (2) of Small Businesses in moderate-income census tract.” 53
Spoiler Alert To find our last number, we can run the Summary Report just as we did before. “During the review period, the bank originated 1,363 Small Business loans totaling $269.9 million within the assessment area.” 54 Notice: I changed my active file.
Spoiler Alert Tables 8 – 10 cover Borrower Distribution of Home Purchase, Home Improvement, and Refinance loans. Notice, now we are comparing to % of Families. 55
Spoiler Alert Our Borrower Distribution write up could reflect the following: “During the review period, the bank originated 359 home purchase loans totaling $52.3 million within the assessment area. The bank originated 13.37% (1) of these loans to low-income borrowers compared to 20.37% (2) of low-income families. Additionally, the bank originated 18.38% (1) of loans to moderate-income families. This is above the 18.11% (2) of moderate-income families within the assessment area. It should be noted that 8.18% of families are considered below the poverty level within the Pittsburgh AA.” 56
Spoiler Alert Remember the Demographics by Tract Category Report? Families Below the Poverty Level comes into play when adding context to Borrower Distribution. 57
Spoiler Alert Tables 11 & 12 cover Borrower Distribution of Small Loans to Businesses and Small Farms. The focus changes to Businesses with Revenues of $1 million or less. The Chart also shows a breakout of the banks loans by Original balance so you can point out the % of loans for $100k or Less (true small business loans). The right side still shows market share and aggregate lending percentages. 58 123
Spoiler Alert Now our context may look like this….. “During the review period, the bank originated 1,363 Small Business loans totaling $269.9 million within the assessment area. During the review period, 55.76% (1) of the Bank’s small business loans were to businesses with revenues of $1 million or less. This percentage is lower than then the 73.93% (2) of businesses. However, 51.06% (3) of the Bank’s loans were for a loan size of $100,000 or less, the amount truly needed for small businesses.” 59
Spoiler Alert You’ve heard it before….. “There are no ratios or published benchmarks that you can look at to say ‘Yes, you are doing a great job!’. 60
Spoiler Alert But there are clues. Review your bank’s last Performance Evaluation. Look for key words: – Excellent – Good – Adequate – Poor – Very Poor These words directly correlate to the rating. 61 = Outstanding =High Satisfactory =Low Satisfactory =Needs to Improve =Substantial Noncompliance
Spoiler Alert Tables 15 reflects the Distribution of Branch Delivery Systems, Openings and Closings. Branches are set up under the main menu>Setup>Branch Locations. 62
Spoiler Alert You will want to verify the Branch information is up to date prior to running Table 15. If you need to edit any information, select Edit. 63
Spoiler Alert!!! Now that you are armed with all the information… 64