1. Community Reinvestment Act (CRA)
By:
Darlia Fogarty, director of compliance and COO
KNOWLEDGE. CLARITY. RELIABILITY.
(888)

2. Community Reinvestment Act (CRA) Background
The Community Reinvestment Act (CRA) was enacted by Congress in 1977 and is implemented by Regulation BB (12 CFR 228). It has fostered access to financial services for low- and moderate-income communities across the country and ensured that banks meet the credit needs of their entire communities.

3. CRA Overview
Congress required each appropriate federal financial supervisory agency to assess an institution's record of helping to meet the credit needs of the local communities in which the financial institution is chartered, consistent with a safe and sound operation, and to take this record into account in the agency's evaluation of an application for a deposit facility by the institution.

4. CRA Overview The Community Reinvestment Act (CRA):
Establishes the framework and criteria by which a federal regulator assesses a bank’s record of helping meet the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with the safe and sound operation of the bank; and
Provide that the bank’s federal regulator takes that record into account in considering certain applications.

5. CRA Overview The bank’s record of CRA performance also Affects:
Applications for:
Establishing a domestic branch by a state member bank; and
Merger, consolidation, acquisition of assets, or assumption of liabilities requiring approval under the Bank Merger Act if the acquiring, assuming, or resulting bank is to be a state member bank; and

6. CRA Overview
Each insured depository institution controlled by an applicant and subsidiary bank or savings association proposed to be controlled by an applicant:
To become a bank holding company in a transaction that requires approval under section 3 of the Bank Holding Company Act;
To acquire ownership or control of shares or all or substantially all of the assets of a bank, to cause a bank to become a subsidiary of a bank holding company, or to merge or consolidate a bank holding company with any other bank holding company in a transaction that requires approval under section 3 of the Bank Holding Company Act; and
To own, control or operate a savings association in a transaction that requires approval under section 4 of the Bank Holding Company Act.

7. Board of Director’s Responsibilities
The Board of Directors has the ultimate responsibility to ensure the proper management of the Bank’s CRA Program.
The Board of Directors is responsible for:
Ensuring the quality of the Bank’s CRA Program;
Designating a qualified CRA Officer;
Maintaining a working knowledge of the Bank’s CRA Program; and
Reviewing for formal adoption the written policies necessary to ensure effective adherence with applicable compliance laws and regulations.

8. CRA Officer Responsibilities
Senior Management through the directive issued by the Board of Directors has elected a CRA Officer to supervise the overall management of the Bank’s CRA Program.
The CRA Officer is responsible for:
Direct supervision of all Bank related CRA duties, programs, software systems, support materials and documentation, etc.;
Developing, implementing, and maintaining detailed CRA tracking and recordkeeping procedures;
Reviewing any related Bank policies and procedures to ensure compliance with the Bank’s CRA Program requirements;
Assigning the training for Bank personnel on CRA Program directives; and
Supporting an independent CRA audit program.

9. Asset-size Classification
Financial institutions are evaluated under different CRA examinations procedures based upon their asset-size classification. Those meeting the small and intermediate small asset-size threshold are not subject to the reporting requirements applicable to large banks. Any institution may opt to be examined as a large institution, provided it has collected and reported the required CRA loan data.

10. CRA Annual Asset Threshold Adjustment
Annually, regulators adjust the asset-size thresholds based on the change in the average of the Consumer Price Index (CPI) for urban wage earners and clerical workers, not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million.

11. Annual Asset-Size Thresholds Adjustments – Effective Jan. 1, 2017
Small Institution
Is a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.226 billion.
Intermediate small institution
Is a small institution with assets of at least $307 million as of December 31 of both of the prior two calendar years, and less than $1.226 billion as of December 31 of either of the prior two calendar years.
Since there is no CRA loan data requirement for an intermediate small institution, its next examination is under the intermediate small institution test even if that examination comes due during the institution’s first year as an intermediate small institution.
Large institutions
Have total assets of at least $1.226 billion for December 31 of both of the prior two years.
Large institutions are subject to CRA data collection. Thus they cannot be examined under the large institution test until they have at least one full year of data collected.
In addition, any size institution may opt to be examined as a large institution provided it has collected and reported the required CRA loan data.

12. Small institution – lending test only
Examples
Determining CRA Type using 2017 Thresholds
Institution
Total Assets 12/31/2016
Total Assets 12/31/2015
CRA Type as of 1/1/2017
Institution A
$310 million
$290 million
Small institution – lending test only
Institution B
$1.025 billion
$900 Million
Intermediate small
institution
Institution C
$1.300 billion
Institution D
$1.500 billion
Large institution

13. Performance Criteria Small Banks – Small Bank Lending Test
Loan to Deposit Ratio
Assessment Area Concentration
Borrower’s Profile
Geographic Distribution
Complaint Response
ISBs – Small Bank Lending Test and Community Development Test

14. Performance Criteria Lending Test: Investment Test: Service Test:
Carries the most weight, approximately 50% of the overall rating. 
Considers overall lending activity, geographic and borrower distribution of loans, community development lending and innovative or flexible lending practices. 
Investment Test:
Considers qualified investments including charitable contributions and equity investments focusing on the dollar amount of the investments, the innovativeness or complexity of qualified investments and the responsiveness to community development needs. (The institution may opt to include affiliate’s investment portfolio).
Service Test:
Focuses on the distribution of the bank’s branches among low-, moderate-, middle- and upper-income geographic areas; the bank’s record of opening and closing branches, and the availability and effectiveness of alternate delivery systems such as ATMs and on-line banking capabilities.

15. Performance Criteria
Wholesale/Limited Purpose Banks – Community Development Test
Institutions with an Approved Strategic Plan – Performance Goals

16. Strategic Plan Institutions
The CRA Strategic Plan (the “Plan”) option allows an institution to develop a plan with the community input detailing how the institution proposes to meet its CRA obligation.
The plan is tailored to the needs of the community using direct community input at the development stage.
The institution informally seeks suggestions from the public while developing the plan and once developed it must publish notice of the plan and solicit written public comment for at least 30 days.
After the comment period, the institution submits the plan to its regulator for review and approval.
NOTE: The Plan requires approval from the bank’s Board of Directors.

17. Strategic Plan Contents
The bank’s plan contains, at minimum:
A term of no more than five years, and any multi-year plan must include annual interim measurable goals under which the Bank’s federal regulator will evaluate the bank's performance;
In the event the Bank has more than one assessment area, it will prepare a single plan for all of its assessment areas or one or more plans for one or more of its assessment areas; and
Affiliated banks will prepare a joint plan if the plan provides measurable goals for each bank. Activities may be allocated among banks, provided that the same activities are not considered for more than one bank.

18. Assessment Area Delineation
A bank is required to delineate one or more assessment areas in which its CRA performance will be evaluated. These assessment areas will be evaluated by the bank’s federal regulator to determine if the bank is meeting the credit needs of its community.

19. Assessment Area Delineation
A bank’s assessment area should include the geographic areas (i.e., census tracts) in which the bank has its:
Main office;
Branches;
Deposit-taking ATM’s; and
The surrounding geographic areas in which the bank has originated or purchased a substantial portion of its loans.
An assessment area will generally consist of one or more metropolitan statistical areas (MSA) or metropolitan divisions or one or more contiguous political subdivisions, such as counties, cities or towns.
A bank may adjust the boundaries of its assessment area to include only the portion of a political subdivision that it reasonably can be expected to serve based on its business model and asset size.

20. Limitations on Assessment Area Delineation
The assessment area is based on geographic considerations and must consist only of whole geographic areas.
It may not:
Reflect illegal discrimination;
Arbitrarily exclude low- or moderate-income geographic areas; or
Extend substantially beyond an MSA boundary.
An assessment area may not extend beyond a state boundary unless the assessment area is located in a multistate MSA.
It is important to note that a minority-owned bank may not identify a specific ethnic group rather than a geographic area as its assessment area and should ensure that it does not exclude other minorities or non-minorities that reside within its assessment area.

21. Annual Review of Assessment Area
Annually, the bank may review and adjust its assessment area to ensure that it is still reasonable.
A more frequent review may be performed particularly as the bank experiences:
Growth, either through opening a new branch, establishing an offsite proprietary ATM, acquisition or the geographic expansion of its loan volume.
Decrease, due to branch closure, or a regulatory CRA examination in which a bank’s assessment area delineation is determined to be inappropriate or not in compliance with the regulation.

22. Bank Required to Collect/Report Data
All state member banks, state nonmember banks, national banks, and savings associations that meet or exceed the asset size thresholds for both of the prior two (2) calendar years are subject to the data collection and reporting requirements of the CRA. Institutions that do not meet or exceed the asset size threshold have the option of submitting data voluntarily. An institution that submits data voluntarily retains the option of being examined as a large institution.

23. Reporting Requirements
At a minimum, an institution must submit, in electronic format:
A transmittal sheet (including the bank’s Reporter’s Identification (RID) number);
A definition of its assessment area(s);
A record of its Community Devel­opment (CD) loans. (If an institu­tion does not have CD loans to report, the record should be sent with “0” in the CD loan composite data fields); and
Information on small business and small farm loans, if applicable.

24. Reporting Requirements
CRA data are aggregated on the census tract level. Each tract rep­resents one record in an entire data submission. For example:
Six different small business loans made in the same census tract constitute one composite record.
Six different small farm loans, three in one census tract and three in another, constitute two composite records.

25. Small Business and Small Farm Loans
Small business and small farm loans that are refinanced or renewed should be collected and reported by a bank as loan originations. When reporting small business and small farm data, a bank may only report one origination (including a renewal or refinancing treated as an origination) per loan per year, unless an increase in the loan amount is granted. A refinancing generally occurs when the existing loan obligation or note is satisfied and a new note is written, while a renewal refers to an extension of the term of a loan. It is no longer necessary to distinguish between small business and small farm.

26. Lines of Credit Lines of credit (and renewals):
Must be collected and reported in the same way as data on loan originations.
Are considered originated at the time the line is approved or increased, and an increase is considered a new origination.
Generally, the full amount of the credit line is the amount that is considered originated.
In the case of an increase to an existing line, the amount of the increase is the amount that is considered originated and that amount should be reported.
However, consistent with the Call Report instructions, a bank would not report an increase to a small business or small farm line of credit if the increase would cause the total line of credit to exceed $1 million, or $500,000 in the case of a small farm line. Of course, a bank may provide information about such line increases to an examiner as “other loan data.”

27. Loan Information Required to be Reported
Small Business and Small Farm:
For each geography in which the bank originated or purchased a small business or small farm loan (segregated), the aggregate number and amount of loans: 
With an amount at origination of $100,000 or less; 
With amount at origination of more than $100,000 but less than or equal to $250,000; 
With an amount at origination of more than $250,000 but not more than $1 million, as to small business loans, or $500,000, as to small farm loans; and 
With gross annual revenues of $1 million or less (using the revenues the Bank considered in making its credit decision).

28. Loan Information Required to be Reported
Community Development Loan Data:
The aggregate number and amount of community development loans originated or purchased.
Home Mortgage Loans:
The location of each home mortgage loan application, origination, or purchase outside the MSAs in which the bank has a home or branch office (or outside any MSA).

29. Optional Data Collection and Maintenance
Consumer loans: A bank may collect and maintain, in electronic format, data for consumer loans originated or purchased by the bank for consideration under the lending test.
A bank may maintain data for one or more of the following categories of consumer loans:
motor vehicle;
credit card;
home equity;
other secured; and
other unsecured.

30. Optional Data Collection and Maintenance
If the bank maintains data for loans in a certain category, it shall maintain data for all loans originated or purchased within that category.
The bank shall maintain data separately for each category, including for each loan:
A unique number or alpha-numeric symbol that can be used to identify the relevant loan file;
The loan amount at origination or purchase;
The loan location; and
The gross annual income of the borrower that the bank considered in making its credit decision.
The gross annual income of the borrower that the bank considered in making its credit decision

31. Data on Affiliated Lending
A bank that elects to have the Federal Reserve Board (the “Board”) consider loans by an affiliate, for purposes of the lending or community development test or an approved strategic plan, shall collect, maintain, and report for those loans the data that the bank would have collected, maintained, and reported pursuant to the guidelines had the loans been originated or purchased by the bank. The Bank shall also be prepared to identify the home mortgage loans reported by the affiliate.

32. Data on Lending by a Consortium or Third Party
A bank that elects to have the Board consider community development loans by a consortium or third party, for purposes of the lending or community development tests or an approved strategic plan, shall report for those loans the data that the Bank would have reported pursuant to the above guidelines had the loans been originated or purchased by the Bank.

33. Report Submission Deadline
Data for a given year must be submitted to the Board, the designated processor for all of the agencies, by March 1 of the following year.

34. Edit Validation Rules for Data Submission
An institution choosing to create an electronic data submission must edit data using the CRA Edit Validation Rules.
Edit validations are divided into three edit types:
Syntactical,
Validity, and
Quality.
Each type corresponds to errors of a different degree of severity, and each must be thoroughly understood to ensure that the data are accurate and complete.

35. Edit Validation Types Syntactical (S) Validity (V) Quality (Q)
Records that contain errors that may prevent them from being uploaded to the FFIEC database.
Errors range from incorrect activity years to duplicate property locations.
Records will not be reflected in your disclosure statement until the appropriate corrections have been made.
Validity (V)
Records containing incorrect information.
Most common validity errors are incorrect census tracts.
Quality (Q)
Loan information that, while it may pass all syntactical and validity edits, is statistically unusual and is subject to further investigation or review to confirm correctness.
For a majority of the quality edits, if the data are correct, no changes are necessary and the data will be reflected.

36. CRA Data Entry Software
The FFIEC makes available free CRA Data Entry Software to any institution that wishes to use it. The software includes several basic analytical reports regarding an institution’s data. The latest version of the CRA Data Entry Software can be downloaded, free of charge, from the FFIEC website. NOTE: If an institution finds that the FFIEC’s software does not meet its needs, it may create a data submission using the File Specifications and Edit Validation Rules that have been set forth to assist with electronic data submissions.

37. CRA Disclosure Statement
The CRA requires certain lending institutions to make annual public disclosures of their small business, small farm and community development lending activity.

38. Content of CRA Disclosure Statements
The Disclosure Statement may contain up to eight tables as follows:
Small Business Loans by County
Originations 
Purchases 
Small Farm Loans by County
Originations
Assessment Area/Non-Assessment Area Activity - Small Business Loans 
Assessment Area/Non-Assessment Area Activity - Small Farm Loans 
Community Development/Consortium Third-Party Activity
Assessment Area(s) by Tract

39. Disclosure Statement Accuracy
An institution's disclosure statement will only contain records that are free of validity errors. The Federal Reserve Board provides an error report to institutions whose data contains validity errors. These institutions are expected to return an error-free submission of their data prior to the release of the data to the public. Errors that remain at the time the data are released will be displayed on the Error Status table.

40. Disclosure Statement Availability
The CRA requires that the Disclosure Statement be made available to the public as part of an institution's CRA public file. The entire disclosure statement must be available at the main office and, if an interstate institution, at one branch office in each state within three business days of its receipt from the Federal Reserve Board. In addition, a report must be made available at a branch office within 5 calendar days of a request being made at that branch.

41. Aggregate Disclosure Statements
The Federal Reserve Board, in conjunction with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision, prepares annually, for each MSA (including an MSA that crosses a state boundary) and the non-metropolitan portion of each state, an aggregate disclosure statement of small business and small farm lending by all institutions.
These disclosure statements indicate the number and amount of all small business and small farm loans originated or purchased by reporting institutions for each geography.
The regulators may adjust the form of the disclosure if necessary, because of special circumstances, to protect the privacy of a borrower or the competitive position of an institution.

42. Central Data Depositories
The Federal Reserve Board makes the aggregate disclosure statements and the individual bank CRA Disclosure Statements available to the public at central data depositories.
The Federal Reserve Board publishes a list of the depositories at which the statements are available.

43. CRA Public File Location
A Bank is required to maintain and, upon request, make available for public inspection a complete CRA Public File (the “Public File”) at the main office location (defined as the principal office designated in its charter) and in at least one branch for every state in which the bank operates. 
A bank shall ensure that the information required by the CRA is current as of April 1 of each year.
Upon request, a bank shall provide copies, either on paper or in another form acceptable to the person making the request, of the information in its public file. The bank may charge a reasonable fee not to exceed the cost of copying and mailing (if applicable).

44. CRA Public File Location
At each branch:
A copy of the public section of the Bank's most recent CRA Performance Evaluation and a list of services provided by the branch; and
All the information in the public file relating to the assessment area in which the branch is located.
To be provided within five calendar days of the request.
NOTE: The Bank may also keep all or part of its public file on an intranet or the Internet (its website) in addition to the above location and paper requirements.

45. Public File Content
Written comments received from the public and banks responses to comments:
Specifically relating to the Bank’s performance in helping to meeting community needs and any response to the comments by the bank.
Current year and the prior two (2) calendar years.
NOTE: Do not publish comments nor responses that contain statements that:
Reflect adversely on the good name or reputation of any persons other than the Bank; or
Contain information which would violate specific provisions of the law.

46. Public File Content
A copy of the public section of the bank's most recent CRA Performance Evaluation prepared by the FDIC.
The copy shall be placed in the public file within 30 business days after its receipt from the FDIC.
A list of the bank's branches:
Include the street addresses and geographic areas.
A list of branches opened or closed by the bank during the current year and each of the prior two (2) calendar years:
Include the street addresses, and geographic areas.

47. Public File Content A list of services: Including hours of operation;
Available loan and deposit products;
Transaction fees) generally offered at the bank's branches; and
Descriptions of material differences in the availability or cost of services at particular branches, if any.
NOTE: At its option, a bank may include information regarding the availability of alternative systems for delivering retail banking services (e.g., banking by computer or telephone, loan production offices, and bank-at-work or bank-by- mail programs);

48. Public File Content
A map of each assessment area showing the boundaries of the area and identifying the geographic areas contained within the area, either on the map or in a separate list; and other information the bank chooses.

49. Additional Information Available to the Public
Banks other than small banks shall include in their public file the following information pertaining to the bank and its affiliates, if applicable, for each of the prior two calendar years:
If the bank has elected to have one or more categories of its consumer loans considered under the lending test, for each of these categories, the number and amount of loans:
To low-, moderate-, middle-, and upper-income individuals;
Located in low-, moderate-, middle-, and upper-income census tracts; and
Located inside and outside the bank's assessment area(s); and
If the Bank elects to have affiliate lending considered, it must include this data in its public file.
The lending data is to cover the Bank's affiliates, in addition as of the Bank itself, considered in the assessment of the CRA performance.
If the Bank has elected to have mortgage loans of an affiliate considered, it must include either the affiliate's HMDA Disclosure Statements for the two (2) prior years or the parts of the Disclosure Statements that relate to the Bank's assessment area(s), at the Banks option.
The bank shall place the CRA Disclosure Statement in the public file within 3 business days of its receipt from the federal regulator.

50. Additional Information Available to the Public
Banks required to report Home Mortgage Disclosure Act (HMDA) data shall include a copy of the HMDA Disclosure Statement provided by the Federal Financial Institutions Examination Council pertaining to the bank for each of the prior two (2) calendar years. In addition, a bank that elected to have the FDIC consider the mortgage lending of an affiliate for any of these years shall include in its public file the affiliate's HMDA Disclosure Statement for those years. The bank shall place the statement(s) in the public file within three business days after receipt.

51. Additional Information Available to the Public
Banks other than small banks shall include in their public file the following information pertaining to the bank and its affiliates, if applicable, for each of the prior two calendar years:
The bank's CRA disclosure statement shows small business and small farm activity as reported to our government agency.

52. Additional Information Available to the Public
A bank required to report home mortgage loan data shall include in its public file a copy of the HMDA Disclosure Statement provided by the Federal Financial Institutions Examination Council pertaining to the bank for each of the prior two calendar years. In addition, a bank that elected to have the Board consider the mortgage lending of an affiliate for any of these years shall include in its public file the affiliate's HMDA Disclosure Statement for those years.

53. Lobby Notice of Public File Availability
A bank shall post a notice in the public lobby of their offices informing the public of the availability of the CRA public file.
Regulation BB, Appendix B includes suggested text for two versions of the lobby notice:
Notice for main offices and, if an interstate bank, one branch office in each state.
Notice for branch offices.

54. Complaints
Any complaint which addresses the Bank’s CRA performance is to be given prompt, courteous and fair attention. This includes complaints from customers, non-customers, community groups, or a banking regulator.
Examples of complaints relating to the Bank’s CRA performance are as follows:
A complaint that the Bank has demonstrated discriminatory practices in making a credit decision or in making credit available;
A complaint of any nature received from a community organization;
A complaint that refers directly or indirectly to the Community Reinvestment Act;
A complaint that a particular credit product is not offered by the Bank;

55. Complaints
A compliant referencing the Bank’s activities in a particular geographic area;
A complaint that in any way alludes to discrimination, other than strictly in the employment context;
A complaint about the Bank’s business days or hours or branch location(s);
A complaint concerning the Bank’s response to a real estate secured loan request, in particular a residential mortgage, residential construction, home improvement or home equity loan or line of credit; and
A complaint concerning the Bank’s response to an applicant for small business credit.

56. Complaint Procedures for CRA
Verbal or written complaint(s) received that impact the Bank’s CRA performance are to be immediately referred to the Bank’s CRA Officer.
The CRA Officer is responsible for handling the complaint and issuing a response.
The CRA Officer is to ensure that the Bank’s Compliance Officer is also notified and copied on the complaint and response.
Any complaint affecting the Bank’s CRA performance is a serious matter and is to be provided immediate attention until the problem is resolved to the satisfaction of all parties to the extent possible.
The CRA Officer is to ensure that the written complaint and response are routed to the Bank’s CRA Public File at all branch office locations.

57. Charitable Contributions
It is the responsibility of the Compliance committee, if applicable, and CRA Officer to:
Administer the Bank’s charitable contribution program, including the development and maintenance of policies and procedures;
Prepare and submit on a periodic basis the charitable contributions budget for the Board of Directors approval. This budget is to include a monetary limit for contributions to a single organization;
Evaluate whether a charitable request meets the Bank’s eligibility criteria standards, is a qualified investment for CRA purposes, and approve or decline such requests;
Approve or decline charitable contribution requests that are not specifically included in the Bank’s approved budget;
Report to the Board of Directors on a periodic basis regarding the state of the Bank’s charitable contributions program; and
Provide training to all Bank personnel regarding the directives and scope of this policy.

58. Program Status Reporting Requirements
The CRA Officer is responsible for reporting the following information to Senior Management and the committee periodically throughout the year:
The dollar amount and number of charitable contributions that are qualified investments for CRA purposes;
The amount of funding received by each organization year to date;
Any non-budgeted contributions that were approved by Senior Management or the committee;
Remaining balance of the charitable contributions budget as of the current period;
The overall distribution of the Bank’s charitable contributions by the type of service provided to the community;
A brief description of each organization as to the type of service provided to the community; and
Any requests for charitable contributions that were denied.

59. Training
The CRA Officer is responsible for ensuring that the Bank’s lending staff applies CRA and fair lending standards in all credit activities and decisions.
The Board of Directors and Senior Management are to be kept informed of the Bank’s CRA goals and performance. The CRA Officer will review with the Board of Directors and Senior Management on a periodic basis the effectiveness of the Bank’s CRA Program.
Branch and Department Managers and Lending Officers must have a good understanding of both CRA and fair lending laws, as they are primarily responsible for accomplishing the performance standards required for a satisfactory or outstanding rating.
All other Bank personnel are to know the identity of the Bank’s CRA Officer and the location of the Bank’s public CRA file and public notices.

60. Training
All employees are required to complete training. It is the responsibility of the CRA OFFICER to communicate to branch and department management personnel through internal memorandum of when training is to take place and when it is to be completed.
All officers of the Bank are responsible for the complete comprehension of this policy and for verifying their employees understand their responsibilities.
NOTE: If at any time an employee has difficulty with a customer or is uncertain about the proper method of handling a situation or transaction, he or she should refer the issue to their immediate supervisor or contact the CRA Officer for further clarification.

61. Definitions of CRA Ratings
In connection with the assessment of each insured depository institution's CRA performance, a rating is assigned from the following group:
Outstanding record of meeting community credit needs.
An institution in this group has an outstanding record of, and is a leader in, ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.
Satisfactory record of meeting community credit needs.
An institution in this group has a satisfactory record of ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.
Needs to improve record of meeting community credit needs.
An institution in this group needs to improve its overall record of ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.

62. Helpful Links
FFIEC - Community Reinvestment Act (Includes information about the regulation and its interpretation and information on CRA examinations.)
FFIEC CRA Data Entry Software - (CRA Data Entry Software to assist respondents in automating the filing of their CRA data.) 

63. Questions?
If you have any additional questions, contact Compliance Alliance at or