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#1265988 - 10/14/09 01:30 AM OCC ratings
nycra Offline
New Poster
Joined: Jun 2007
Posts: 19
Do any OCC rated banks have a view on what the agency is currently requiring for an outstanding rating, with regard to community development loans vs % tier 1 capital(understanding, of course, that qualitative factors are also considered)?

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CRA
#1266002 - 10/14/09 03:14 AM Re: OCC ratings nycra
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
We have many OCC-regulated bank clients and I can tell you that what is required depends on your "performance context". There is no universal standard and if you ask anyone from the OCC or any regulatory agency I am certain that you will get the same answer.

Having said that I suggest two things: (1) visit GeoDataVision Community Development Lending Market Report and review the reported Community Development Lending of every CRA reporting lender in the country including market rank and ratio to assets that allow you to compare banks of all sizes in terms of the relative importance of their CD lending in comparison to their size and (2) develop a "Community Needs Assessment" to establish your CD performance standards. A well-done community needs assessment will be appreciated by examiners and it would be an excellent basis for establishing and defending your own performance standards. "Carpe Diem", seize the day and control your own destiny!
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