I would like to ask all Large Institutions how they analyze their CRA investment/contribution levels and determine what level of performance is satisfactory and what level is outstanding.

My bank is a community bank which is comprised of regions with their own President/CEO and their own budgets. I am interested in not only analyzing our performance for the bank as a whole, but also by individual MSAs, and by the regions themselves.

Is there a 'best practices' calculation to determine performance? Could it be based of a percentage of total assets (10% would be needs improvement, 20% satisfactory, etc)? Or would a fixed dollar amount based on number of branches be better, etc? Any guidance is appreciated.

The best thing to do is compare your bank to your peers by pulling their performance evaluations. You can do that by MSA, by regions, etc. by selecting banks of similar size in each geographic area. Prepare a chart with investments, CD loans, etc. and include asset size/% of assets for each category and rating received.

Every regulator will deny that there is any universal quantitative performance standard. You can formulate some general rule of thumb, but you really need to develop a Community Needs Assessment because every situation is unique. There are some things you can do in the meantime. For example, you could examine all the CD lending reported by banks in your state. GeoDataVision has reports for CD lending showing market rank, number and value of CD loans and ratio to assets for each and every state. The reports are on our website and are available for free under Bankers Tools on the website. This would give you a quick and easy perspective on what other reporting lenders have been doing and is a good starting point. Moreover, because the reports contain calculations relative to bank size it allows you to more readily compare your results to banks of different sizes.

I have tried to put other bank's levels of investment based on their PE's and tried to find a correlation. But there are too many variable. Prior period investments are obviously not given as much credit as current period. Investments that meet defined community needs weigh more than those that do not. Regional investments do not get as much credit as those directly within your assessment area. Basically, it's almost impossible to find rhyme or reason for the different ratings.

Getting back to Sano's ideas, I don't think it is a good idea to base it on number of branches, unless you are simply attempting to allocate internally.

You must be meeting the identified needs in your AA, and you should be at the top in your peer group if you want an outstanding.

The CRA Questions and Answers state that prior period investments are to be considered the same as current period investments. See Q&A ___ .12(t)- 8.

We are regulated by the OCC and they do not give us as much credit for prior period.