CRA WORKSHOP. Managing Your Bank s CRA Performance

Transcription

1 CRA WORKSHOP Managing Your Bank s CRA Performance 2

2 Agenda Issues Affecting CRA Performance Achieving an Outstanding Rating CRA Outreach/Resources Q&A 3 Performance Context: CRA Performance is a broad range of economic, demographic, and institution and community specific information that an examiner reviews to understand the context in which an institution's record of performance should be evaluated under the CRA. 4

3 Performance Context What is your Story? 5 Performance Context (Cont.) The Content of the Story Bank Characteristics Community Characteristics: economic conditions demographics perspectives from community leaders 6

4 Performance Context (Cont.) Bank Characteristics Business Strategy Financial Composition Products and Services Competitive Advantages Supervisory Concerns 7 Performance Context (Cont.) Community Characteristics Community Contacts Economic Factors Demographics Performance Context 8

5 Changes to the Story Line Your Story is always changing and evolving. Economic Impact of the Financial Crisis Pending Regulations Census Changes: new income level tract designations new borrower characteristics 9 Changes to the Story Line (Cont.) Reduced Mortgage Lending Activity 10 th District Total # of Mortgage Originations (HMDA) 10

6 Changes to the Story Line (Cont.) Reduced Mortgage Applications 10 th District Total # of Mortgage Denials 11 Changes to the Story Line (Cont.) Your Story is always changing and evolving. Economic Impact of the Financial Crisis Pending Regulations Census Changes: new income level tract designations new borrower characteristics 12

7 Changes to the Story Line (Cont.) 10 TH District Tract Changes 13 Source: 2000 Census Data and available FFIEC Data Changes to the Story Line (Cont.) 10th District Percentage of Tract Changes by State Colorado Kansas Missouri* Nebraska New Oklahoma Wyoming Mexico* District 14 *Includes only tracts located in the 10 th District Source: 2000 Census Data and available 2012 FFIEC Data

8 Changes to the Story Line (Cont.) Denver MSA Tract Demographic Comparison 2000 US Census vs. ACS % Located in Tract Category > Low Moderate Middle Upper Demographic Data: Owner Occ Units Families Households Achieving an Outstanding Rating 16

9 Achieving an Outstanding Rating (Cont.) Small Bank Options: 1. The Retail Lending Test 2. The Retail Lending Test + 3. The Large Bank Test 17 Achieving an Outstanding Rating (Cont.) BUT: A bank s CRA performance can be adversely affected by evidence of discriminatory or other illegal credit practices. Benefits: reputation examination cycle 18

10 Outreach / Resources Kansas City Fed Events: CRA Roundtables CRA 101 Workshops Investment Connections: o To subscribe ariel.cisneros@kc.frb.org Conferences: National Interagency Community Reinvestment Conference (biannually): o 19 Outreach / Resources (Cont.) CA Letters: FFIEC Census Reports: CRA Ratings Search: CRA Examination Procedures: Kansas City Fed Community Resources: 20

11 Outreach / Resources (Cont.) Demographic information for small communities: Housing information by state: Labor statistics: National Center for Educational Statistics (Search Schools): 21 Outreach / Resources (Cont.) Census Mapping: Policy Map Widget Assessment Area Mapping: Policy Map Widget School Districts: 470A37A32469CDBBF35&state=KS&altLayout=true 22

12 23 QUESTIONS