Fifth Third's 2014 (yes 2014) CRA exam report was released last week. While the CRA ratings for lending, investments and services were outstanding and high satisfactory, fair lending and UDAAP factors brought that rating down to needs to improve. Those items were dealer pricing and credit card add on products, and allegations that the bank engaged in a pattern or practice of discrimination in violation of ECOA and the Fair Housing Act on the basis of disability and the receipt of public assistance.
The evaluation of the factors that are part of the actual CRA performance lists:
The major factors supporting the institution’s rating include:
• A good responsiveness to credit needs;
• An adequate geographic distribution of loans throughout the assessment area;
• A good distribution of loans among borrowers of different income levels and an adequate distribution of loans to businesses and farms of different revenue sizes;
• A leader in making community development loans;
• An excellent level of qualified community development investments and grants;
• A leadership role in providing community development investments and grants;
• Retail delivery systems that are accessible to all geographies and individuals of different income levels and businesses of different revenue sizes;
• A record of opening and closing banking centers that has improved the accessibility of delivery systems;
• Banking services and hours that do not vary in a way that inconveniences any portions of the assessment areas; and,
• A leader in providing community development services.
So of course any merger plans are on hold until the next examination, which hopefully won't take several years to complete and publish..
Another case showing that CRA is not just tasks completed in a vacuum. The excellent CRA work can get derailed by other actions.
The FRB has not published the exam report on its site yet. It is available on Fifth Third's website:https://www.53.com/about/in-the-community/community-reinvestment-act.html