SARC-96-04 (June 26, 1996)
The Supervisory Appeals Review Committee (鈥淐ommittee鈥) of the Federal Deposit Insurance Corporation (鈥湺啾τ蜗废略剽), on June 21, 1996, considered your appeal of the Community Reinvestment Act (鈥淐RA鈥) rating issued to [Bank] (鈥淏ank鈥), pursuant to the Compliance Examination Report (鈥淩eport鈥) as of August 18, 1995.
The Committee, after a review of the material submitted with the appeal, has concluded that the CRA rating should be affirmed. This decision is considered a final supervisory determination by the 多宝游戏下载.
The Committee reached its determination after due consideration of the information presented by the Bank and the material contained in the examination report. While it was evident to the Committee that the Bank鈥檚 overall lending performance was satisfactory, the Committee concluded that the performance was insufficient to warrant an increase in the overall rating to an 鈥淥utstanding.鈥 Considered in reaching this conclusion was the Bank鈥檚 conservative lending policy and restrictive lending terms that contribute to a relative low loan volume within the community.
The committee notes that the appeal was submitted well after the time frames contained in the 多宝游戏下载鈥檚 Guidelines for Appeals of Material Supervisory Determinations (鈥淕uidelines鈥). It is further noted that avenues of communication through the regional office were not pursued by the Bank with regard to the appeal and the related report of examination. The Committee wanted to share its view that the examination and appeals process work more effectively if there is open communication between the bank and the regional office and issues are presented and addressed in a timely manner at that level.
By direction of the Supervisory Appeals Review Committee of the Federal Deposit Insurance Corporation.