New Community Reinvestment Act rules take effect today, after five years in the making.
Bankers have been preparing for the lending component since April 1995, when regulators adopted the revisions. But they are still unsure how the investment and service tests will work.
"We are nervous," said Catherine P. Bessant, president of community investment for NationsBank Corp. "But it is not nervous over whether we are doing a good job. It is nervous over whether the test will capture our performance."
The rules base half of a large bank's CRA grade on lending in its community; the other half is derived by looking at how the bank invests and serves its market.
The three-pronged test replaces 12 assessment factors, which emphasized paperwork-intensive activities such as recording meetings with community leaders in memos.
President Clinton broached the idea of rewriting the CRA rules even before taking office. The banking agencies spent 1993 through 1995 rewriting the regulation and agreed to phase-in the new rules over 18 months.
Banks with less than $250 million of assets started complying in January 1996 with streamlined exams focused almost entirely on lending.
The rules that take effect today apply to larger banks.
Under the lending test, examiners will look at the number and amount of loan originations, where loans were made, and the income level of recipients. Banks are not required to extend credit in every census tract, although regulators will investigate conspicuous gaps.
Examiners will compare a bank's lending record with the performance of competitors. They also will meet with community, business, civic, and bank officials to determine the credit needs of the region.
The service test rates how well banks deliver products to their community. Examiners will give the most credit to branches and loan production offices, although some credit will be awarded for ATMs, mobile branches, and phone banking facilities. The agencies also will give extra points if a bank offers free checking to low-income consumers or if the institution provides employees to work on community development projects.
Agnus Bundy Scanlan, senior vice president at Fleet Financial Group, said her institution has adopted new branch-closing policies in anticipation of the service test. For example, Fleet holds meetings with community leaders before closing any branches.
The investment test measures how much credit banks extend to community development corporations, and it rewards institutions that purchase mortgage-backed securities and municipal bonds used to fund projects in low-income areas. Examiners will give extra credit if banks fund projects that the private sector was otherwise ignoring, such as new housing for the poor.
No one knows what qualifies under the investment test, said Donald Mullane, executive vice president at BankAmerica Corp. "The mystery is the investment test," he said. "How much is enough, and are we making the right kind of investments? I think we are, and we hope that will be recognized by the examiners."
Ms. Bessant said she is particularly worried about getting credit for loans the bank makes through third-party nonprofit groups, which must record how much of each bank's money goes toward particular loans. "I'm not sure our nonprofit partners are ready for what we need from them," she said.
Stephen M. Cross, deputy comptroller for community and consumer policy at the Office of the Comptroller of the Currency, said bankers have no reason to worry.
"All that will happen is we will emphasize lending records more and processes less," he said. "The preponderance of banks that have really stepped up to the plate during the last five years and developed substantially improved lending records will come out looking even better."
Mr. Cross said examiners have received extensive training, and senior officials in Washington will review all exam reports for at least three months to ensure everyone is treated fairly.
"Examiners are in the same boat as bankers," he said. "Some are a bit anxious because they have not done one of these exams. But they are ready."
More than 95% of banks now hold at least a satisfactory CRA grade. Mr. Cross said it is too early to tell if the new test will result in lower scores.
