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#333145 - 03/14/05 10:35 PM Performance Context
Anonymous
Unregistered

I am in the process of writing up our bank's performance context. I don't want to leave out anything important - can anyone give me suggestions on what all to cover? Thanks.

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CRA
#333146 - 03/14/05 10:40 PM Re: Performance Context
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Have you received your exam request letter? I structure my response to the letter, covering each and every issue they are looking to review, including my stregnths and weaknesses within that line item.

I also do a full PE on myself. This is the best way to prepare a performance context if you do nothing else. In order to prepare a valid PE you'll have to walk through each piece of the performance context as if you were the eyes of the examiner.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#333147 - 03/14/05 11:59 PM Re: Performance Context
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
There are many things that could be included in performance context. You should know the local issues as well as anyone. Make certain that you document them (local economy, unemployment, etc). The areas that are some of the most important pertain to the Lending Test parameters enumerated in CRA. Earlier this year I submitted a tool to BOL "CRA Performance Synopsis" that outlines the specific standards based on particular performance context data. You should know the LMI tract and LMI applicant penetration rates, very small business percentages, etc., because they show what other lenders in your market have done and it is natural to compare your performance to other lenders. So you need to know those numbers and understand how you compare. These numbers are not the beginning and end of performance context data, but they represent explicitly the lending performance of other lenders as measured by the only enumerated standards in the regulation. If the market shows 20% of HMDA reported mortgages were in LMI geographies and your penetration rate is only 5%, you'd better be prepared to explain the disparity. If you are interested, just pm me and I can send you more information.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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