Legal Seminar, Chicago, IL

Assesing CRA Performance

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 Small Banks  Small Banks (that are not Intermediate Small Banks)  Intermediate Small Banks  Wholesale or Limited Purpose Banks  Community Development Test for wholesale or limited purpose banks  Large Banks  Lending, Investment and Service Tests  Alternative  Strategic plan

© 2019 Howard & Howard Attorneys PLLC

Reporting

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 A bank, except a small bank or a bank that was a small bank during the prior calendar year, shall report annually by March 1 to the appropriate federal banking regulator the following data for the prior calendar year:  Small business and small farm loan data  Community development loan data  Home mortgage loans  Optional data collection and maintenance for consumer loans and other loan data  Affiliate lending data may be included if the bank has asked the regulator to consider the affiliate lending in the standard tests  CRA Disclosure Statement – prepared by the appropriate federal banking regulator for each bank that reports data

© 2019 Howard & Howard Attorneys PLLC