The Office of the Comptroller of the Currency ("OCC") notified national banks, federal savings associations, and federal branches and agencies of clarifications to the OCC supervisory policies and processes for Community Reinvestment Act ("CRA") exams. The policies and processes apply to the evaluations of all OCC-supervised banks subject to the CRA.
The policy clarifications addressed certain aspects of the CRA exam process, including:
- full-scope and limited-scope reviews;
- "size" and "purpose" tests for activities that promote economic development;
- the use of demographic, aggregate and market share data for banks that report under the Home Mortgage Disclosure Act;
- the analysis of the borrower distribution of loans outside bank assessment areas;
- required frequency and timing of CRA evaluations;
- the examination of retail and community development activities in the CRA exam period; and
- the evaluation of a bank's lending activities, such as home mortgage lending.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
