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Community Reinvestment Act Performance Review

FinPro's CRA Performance Review is designed to assess an institution's current position relative to the Community Reinvestment Act guidelines with the goal of quantifying its outstanding portfolios, geographic distributions and performance trends.

Proactive Management

The program follows the regulatory examination guidelines and assists an institution in being thoroughly prepared for regulatory examinations and puts management in a position to proactively address regulatory issues.
This review thoroughly evaluates the assessment area to ensure that it meets the regulatory guidelines.

Thorough Performance Evaluation

CRA performance is quantified based on the regulatory criteria and examination guidelines, and covers:
  • Evaluation of the institution's loan-to-deposit ratio.
  • Evaluation of the level of lending within the assessment area, evaluating all loans and deposits, not just those subject to HMDA.
  • Computation of the geographic distribution of the institution's loans to borrowers and geography's of different income levels.
  • Evaluation of HMDA data and trends, both for the Institution and all lenders within the assessment area.
  • Evaluation of Small Business Loan data and trends, both for the Institution and all lenders within the assessment area.
  • Evaluation of the level of Community Development Lending.
  • Evaluation of the use of innovative and flexible lending practices.
  • Evaluation of the level of CRA qualified investments and grants.
  • Evaluation of the criteria for the service test.
  • Summary of the institution's other CRA activities including special products and programs and Community Development Services.
  • Recommendations to improve performance.