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#1494337 - 01/12/11 10:32 PM Re: Still battling with the OCC.... AnonRegulator
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
We have been encouraging banks to develop Community Needs Assessments for their AA's. As AR points out, the first step in establishing you are fulfilling the needs of the community is to identify those needs. How can you demonstrate to examiners that your CD activity is adequate when you have no documentation about those needs?

When we conduct Community Needs Assessments for banks, in addition to the local credit market data (HMDA, small business, small farm and reported CD lending) and demographic data, we interview at least two dozen community groups to get a narrative of what community leaders recognize the needs of the community are. This adds perspective to the "statistical picture" and creates a better understanding of what your institution can do to help your communities with your financial expertise and financial resources.

I am certain examiners appreciate this kind of effort. The examiners have only a limited period of time to develop a picture of the community. Your institutions have been there for decades or more. Don't wait for examiners to develop the picture. Paint it yourself!
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#1494799 - 01/13/11 06:40 PM Re: Still battling with the OCC.... AnonRegulator
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Originally Posted By: AnonRegulator
As pointed out by Pale Rider, section 26(c) discusses how flexibly the CD test will be applied. While it says banks may not simply ignore one or more of these categories of community development, it also says, based on the institution’s assessment of community development needs in its assessment area(s), it may engage in different categories of community development activities that are responsive to those needs and consistent with the institution’s capacity, etc.


This is the exact path I went down Anon. I actually got word earlier today they are changing our rating to satisfactory. Unfortunately, I can't say for sure what made them change their mind, but I'm glad they did. I really did not want this to end up in Washington.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1494810 - 01/13/11 06:45 PM Re: Still battling with the OCC.... ACBbank
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Congratulations on a hard won rating! I am sure you are so pleased they assigned CRA to you at the last minute.
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#1495031 - 01/13/11 09:35 PM Re: Still battling with the OCC.... Kathleen O. Blanchard
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
Amen, congrats ACB
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#1496038 - 01/15/11 02:40 PM Re: Still battling with the OCC.... ACBbank
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
Glad it turned out positively. They probably changed their mind as people up the flagpole started asking questions, considered the wording in the regualation and Qs&As, saw you had a needs assessment, and started feeling a little squeemish about rating the bank NTI. It happens. smile

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#1497689 - 01/20/11 05:01 PM Re: Still battling with the OCC.... AnonRegulator
bOaty Offline
Power Poster
bOaty
Joined: Aug 2006
Posts: 4,266
Chillin an grillin
That's great news ACB!
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#1497799 - 01/20/11 06:05 PM Re: Still battling with the OCC.... bOaty
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Thanks guys. It was a battle, but at least it ended well. I am already taking measures to ensure this doesn't happen again.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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