As is the case each month, the FDIC and OCC have released lists of performance evaluations from financial institutions receiving ratings during September of 2018. Banks and savings associations subject to CRA examinations - and especially their CRA Officers who are responsible for CRA compliance - can greatly benefit from reviewing CRA performance evaluations that their regulators publish on similarly sized banks. Specifically, reviewing Outstanding performance evaluations can often show a bank what unique steps can be taken to get extra CRA credit during an examination while Substantial NonCompliance ratings can explain what an insufficient CRA program looks like.
The FDIC list of CRA evaluations includes a total of sixty-six (66) evaluations. Of those, two (2) banks received Outstanding ratings, one (1) bank received a Needs to Improve rating, and the remaining sixty-three (63) banks received a satisfactory rating.
The OCC list of CRA evaluations includes a total of thirty (30) evaluations including five (5) Outstanding ratings, twenty-three (23) Satisfactory ratings, one (1) Needs to Improve rating, and one (1) Substantial Noncompliance rating. In addition, the OCC data is broken down into bank size, listing the number of banks reviewed: five (5) large banks, ten (10) intermediate small banks, fourteen (14) small banks, and one (1) bank reviewed under a strategic plan.