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#1312248 - 12/23/09 03:00 PM what's wrong with a satis. rating?
Trees Offline
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Joined: Apr 2005
Posts: 4,013
We have received an outstanding for as long as I can remember. Then, someone said to look at the work going into getting this rating versus the rewards. And, to find out what downsides there are if we received a satisfactory rather than an outstanding. Comments welcome!!

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CRA
#1312268 - 12/23/09 03:12 PM Re: what's wrong with a satis. rating? Trees
Pale Rider Offline
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There are no substantial regulatory implications between sat and Outst similar to the enforcement possibilities betweem sat and NTI.
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#1312272 - 12/23/09 03:15 PM Re: what's wrong with a satis. rating? Trees
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
We've received satisfactory ratings for as long as I can remember. When I became the CRA Officer in 2005, the expectation was that I maintain the satisfactory rating, not improve it to an outstanding. Since I've never received an outstanding, I'm not sure what I missing out on. Bragging rights, for sure. It's a struggle for me, someone who strives for perfection, to settle for anything less. But I guess that's what you have to do when you wear so many hats.
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#1312276 - 12/23/09 03:20 PM Re: what's wrong with a satis. rating? Kelsey D
Bullseye Offline
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Originally Posted By: Kelsey D
We've received satisfactory ratings for as long as I can remember. When I became the CRA Officer in 2005, the expectation was that I maintain the satisfactory rating, not improve it to an outstanding. Since I've never received an outstanding, I'm not sure what I missing out on. Bragging rights, for sure. It's a struggle for me, someone who strives for perfection, to settle for anything less. But I guess that's what you have to do when you wear so many hats.


Ditto here!

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#1312286 - 12/23/09 03:26 PM Re: what's wrong with a satis. rating? Bullseye
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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There is no actual benefit to an outstanding benefit to outstanding outside of bragging rights, possible use as a sales tool for certain organizations. Regulatorily speaking it bestows no added "rights".

Many banks choose to take satisfactory, because of the added expense without payback of an outstanding, and the potential negative news of moving from an outstanding to a satisfactory.

A satisfactory is just great!
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#1312471 - 12/23/09 05:38 PM Re: what's wrong with a satis. rating? Kathleen O. Blanchard
Len S Offline
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Joined: Oct 2004
Posts: 1,971
Connecticut
I haven't had time to check this out but I believe a benefit of an outstanding performance rating is a longer time interval between CRA exams.
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#1312522 - 12/23/09 06:09 PM Re: what's wrong with a satis. rating? Len S
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That is significant Len! With 11 legal vehicles up until last year, we are in constant exam mode, so it's hard to determine what kind of interval we get.......shoot, they have permanent offices onsite....
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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#1313083 - 12/24/09 03:21 AM Re: what's wrong with a satis. rating? Pale Rider
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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GLBA mandated cycles for small banks with satisfactory and outstanding ratings.

Here is the OCC statement on exam cycles:

"The OCC’s CRA examination cycle is based on the asset size of the bank. All banks with assets over $250 million are on a risk-based cycle in which examinations are ordinarily started 36 months after the close of the last CRA examination. Banks with total assets of $250 million or less are on a different examination cycle, as mandated by the Gramm–Leach–Bliley Act (GLBA). The GLBA-mandated examination cycle requires the OCC to examine a bank of this size that has a “satisfactory” rating no sooner than 48 months after the close of its last CRA examination, and if it has an “outstanding” CRA rating, no sooner than 60 months after the close of its last CRA examination."

I have seen small banks with satisfactory ratings go 7 years between examinations.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1313084 - 12/24/09 03:24 AM Re: what's wrong with a satis. rating? Kathleen O. Blanchard
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Here is the FED Comment, same thing on GLBA requirements:

Examination Cycles.

"Under the Act, any insured depository institution with $250 million or less in aggregate assets would be subject to routine CRA examinations as follows:

* on a 5-year cycle, if the institution received an “outstanding” rating at its most recent CRA examination; or
* on a 4-year cycle, if the institution received a “satisfactory” rating at its most recent CRA examination.

The Federal banking agencies may conduct non-routine examinations for reasonable cause in such circumstances as they deem appropriate.

Note: Other than changes indicated above, CRA examination cycles remain unchanged. "
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1313667 - 12/28/09 03:27 PM Re: what's wrong with a satis. rating? Kathleen O. Blanchard
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Hmmm. We are a Fed bank, (not OCC OTS, etc.) and are very strong. We seem be be examined every other year for CRA.....and that's with an outstanding rating.

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#1313673 - 12/28/09 03:31 PM Re: what's wrong with a satis. rating? Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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The GLBA rules apply to all small banks, not just OCC/OTS...those are just the two that put the info easily available on their website. If you have assets > $250 million, the standard is 3 years but can be less or a bit more.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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