Lending Carries Most Weight in Revised Ratings

WASHINGTON - Lending grabs center stage in the revised Community Reinvestment Act rating system.

The rules give lending twice as much weight as either service or investment, the other two tests in the new three-pronged approach. In fact, a bank cannot score an overall "satisfactory" unless it receives a high grade on the lending test.

The system relies on the same five ratings as earlier proposals: outstanding, high satisfactory, low satisfactory, needs to improve, and substantial noncompliance.

Regulators have plenty of leeway to decide where a bank falls on the five-point scale. For example, the rules say a bank must have "excellent" loan distribution to qualify for an "outstanding" rating. But it doesn't define what excellent means.

Examiners will assign a numerical score for performance in each of the three areas.

"Outstanding" banks will have received the most points - 12 for lending and six each for service and investment. "High satisfactory" earns nine points for lending and four for the others two tests, and "low satisfactory" means six for lending and three for the others.

"Needs to improve" ratings receive three points for lending and one for the others while "substantial noncompliance" gets zero across the board.

Regulators will add these scores, awarding banks with 20 or more points an overall "outstanding" and those with 11 to 19 points a "satisfactory." Banks with five to 10 points receive a "needs to improve," and those with fewer than five points get "substantial noncompliance."

This point system ensures that an institution cannot win an overall "outstanding rating" unless it receives a "high satisfactory" in the lending test.

The rating system contains one caveat: Any bank that doesn't receive at least a "low satisfactory" on the lending test cannot receive an overall "satisfactory," regardless of the point total.

For reprint and licensing requests for this article, click here.
MORE FROM AMERICAN BANKER