e Federal Reserve System Purposes & Functions 161
Evaluating Performance under the
Community Reinvestment Act
The Community Reinvestment Act encouraged depository institutions—
commercial banks and savings institutions—to help meet the credit
needs of their local communities, including low- and moderate-income
neighborhoods, consistent with safe and sound operations. The CRA
requires the Federal Reserve to evaluate each state member bank’s
CRA performance and assign one of four CRA ratings—Outstanding,
Satisfactory, Needs to Improve, or Substantial Noncompliance. The CRA
rating and conclusions, as well as the facts, data, and analysis that sup-
port the bank’s rating, are summarized in a publicly available perfor-
mance evaluation.
CRA examiners assess a bank’s performance using examination proce-
dures tailored to the bank’s size and the type of business it does. Perfor-
mance is evaluated in the context of the institution and the communities
within which it operates. That means examiners consider information
about the bank’s business strategy, product offerings, capacity, and con-
Box 7.1. Making Compliance with Consumer Laws a Priority
The Federal Reserve’s consumer compli-
ance supervision program is founded on
the expectation that consumer compli-
ance risk management is an integral
part of an institution’s corporate-wide
risk management.
A key goal is ensuring that each institu-
tion is in full compliance with federal
consumer protection laws and regula-
tions and has processes and programs
in place to keep up with new or revised
compliance requirements that may arise
as laws, regulations, and bank products
and services change. Examiners look
for a number of indicators of an
institution’s management of consumer
compliance risk:
• Board of directors and senior man-
agement oversight. Directors have
ultimate responsibility for the risk
taken by their institutions. Examiners
seek to ensure that senior manage-
ment is implementing strategies that
effectively identify and control for
consumer compliance risk.
• Policies and procedures. Examin-
ers seek to ensure that an effective
compliance program is in place with
documented policies, procedures, and
processes for monitoring and control-
ling compliance risks.
• Risk monitoring. Examiners seek
to ensure that information manage-
ment systems provide timely reports
to management on an institution’s
financial condition, operating perfor-
mance, and risk exposure.
• Internal controls. Examiners seek to
ensure that an institution’s internal
control structure allows it to effec-
tively manage its consumer compli-
ance risk, and creates effective lines
of authority and responsibility.
• Training. Examiners seek to ensure
that an institution provides its person-
nel with training regarding rules,
regulations, policies, and procedures
that impact the institution’s business
lines.