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Community Reinvestment Act (CRA) Questions and Answers for Bank Customers

How can I comment on a bank's CRA performance? 

The Office of the Comptroller of the Currency each quarter releases a list of national banks to be examined for compliance with the Community Reinvestment Act (CRA) in the next calendar quarter. This announcement allows interested parties to file public comments about the banks' performance under the CRA. All public comments received before the close of the CRA examination will be considered by the OCC in its evaluation. Comments should be filed with the subject bank or with the appropriate OCC supervisory office.

How can I find a bank's CRA evaluations? 

You can search the CRA Database for a bank's CRA evaluations and ratings.

How can I find out if my bank is scheduled for a CRA examination?  

OCC publishes an advance notice of CRA evaluations coming due each quarter.

What are OCC's responsibilities under the CRA? 

In accordance with safe and sound operations, OCC—

  • Assesses a national bank's record of helping to meet the credit needs of its entire community, including low- and moderate-income neighborhoods; and
  • Considers that record in evaluating a bank's application for new branches, relocation of an existing branch, mergers and consolidations, and other corporate activities.

Does the CRA apply to all depository institutions? 

The CRA applies to depository institutions that carry FDIC deposit insurance.

The CRA does not apply to special purpose banks (12 CFR 25.11), such as bankers banks and banks that—

  • Provide cash management controlled disbursement services, or
  • Serve as correspondent banks, trust companies, or clearing agents 12 USC 24 (Seventh).

How does OCC determine a CRA rating? 

OCC evaluates a financial institution's activities under CRA based on information about—

  • The institution: Its capacity, constraints, business strategies, competitors, and peers; and
  • The community: Its demographic and economic data, and lending, investment, and service opportunities.

OCC uses a four-tiered rating system:

  • Outstanding
  • Satisfactory
  • Needs to Improve
  • Substantial Noncompliance

Interstate banks receive an overall rating as well as an evaluation based on their CRA performance in each state and metropolitan statistical area in which they have branches.

What is included in a CRA performance evaluation? 

The CRA performance evaluation (PE) generally includes a description of the institution and its assessment area(s); its CRA rating; and the facts, data, and analyses supporting the rating.

How often does the OCC conduct a CRA examination? 

In general, the OCC conducts a CRA examination of a national bank every three years. There is an extended examination cycle for smaller banks as follows:

* Mandated by the Gramm-Leach-Bliley Act of 1999.

Is OCC the only federal regulator for the CRA? 

No. The OCC is the federal regulator for national banks and federal savings associations. The following agencies have regulatory responsibilities for other types of financial institutions.

Board of Governors of the Federal Reserve System (FRS)

Regulator for state-charted banks that are members of the Federal Reserve System

Federal Deposit Insurance Corporation (FDIC)

Regulator for insured state banks that are not members of the Federal Reserve System