We will be examined under the small bank, I was actually just wondering as the CRA Officer what information I should be collecting for the examination.....Just Wondering

They will look to see if your Public File is in order (remember to put a map of your assessment area in it). The loan to deposit ratio will be evaluated (you should be putting a listing of this in your public file quarterly). The bulk of the exam will be on your lending. They will look to see the loans made within your assessment area and outside your assessment area. If the percentage made within your assessment area is less than a majority or low then you may have problems. They will also be concerned with your lending within the low to moderate income tracts within your assessment area and small business loans.
The loan sample will be taken from your HMDA reports (if you are a HMDA reporter) and an equal number picked from the loan type you have the most of.

Good Luck

I am also about to be examined in the small bank enviro. My management is having me put together the dollars in loans by zip code to the dollars in deposits. Is this actually necessary? It has taken some time because I have compiled info on the census tracts and now must compile based on zip codes.

Thank you in advance for your response.


Tina A Sweet-Williams
AVP Compliance & CRA Officer
Gold Country Bank, NA
mailto:tsweet@goldcountrynb.com

Analysis is done using census tract codes. Tracts have income classifications, and zip codes do not. There may be several census tracts in a zip code and each can have a different income classification. For CRA analysis purposes stick with the census tracts. Zip codes may be some good marketing information.

Comparing deposits to loans by zip code will not be very useful for CRA purposes. The loan to deposit ratio of the your bank each quarter, will be averaged and compared to other peer institutions.

Zip codes cannot be overlaid with census tracts. Albout all you can do with zip codes is determine which ones are within your assessment area and you can get as estimate on loans inside and outside your assessment area. If nothing else, this can help you keep check on assessment area lending but will not help pinpoint low to moderate income lending.

A map of an assessment area showing census tracts can be made with an overlay showing the zip code boundries. We do it all the time.

Be careful using zip codes as some zip boundries split census tracts, and in some parts of the country they split counties, which may not be in the Assessment Area.