Details, details, details.
Regulators and compliance officers said that's what has been missing from Community Reinvestment Act strategic plans that have been submitted to the agencies. None of the 11 plans have been approved.
"We didn't realize how specific they wanted it to be," said Thomas L. Klaer, director of community reinvestment at Valley American Bank in South Bend, Ind., which submitted a plan in January. "The most important thing is for banks to set goals and put numbers as to what they'll try to accomplish. You have to have dollar goals and number-of-loan goals and try to meet them."
The strategic plan is a new option included in the revised CRA rules that took effect Jan. 1. Institutions determine their own reinvestment goals, subject to agency approval. The system is supposed to allow bankers to establish concrete goals that, if met, will result in a passing grade.
The new CRA rules currently apply only to small banks, which may explain why all the plans are from small institutions, or tiny subsidiaries of huge holding companies. Large banks are not covered until July 1997.
Bobbie Jean Norris, fair-lending chief at the Federal Deposit Insurance Corp., said bankers should set detailed goals. For example, a plan should explain whether a lending goal will be measured as an increase in the number or the value of loans.
She added that phrases such as "Join with community groups to sponsor homeownership counseling" are too vague. Bankers instead should specify how many organizations they hope to work with and how many people they hope to reach, she said.
"The more specificity that is in a plan, the easier it is to complete the review," said Ms. Norris.
According to a letter obtained from the FDIC under the Freedom of Information Act, Valley American needed more demographic data in its plan. The agency asked for analyses of loan applications received in 1993 and 1994, broken down by race. The bank also was asked to supply mortgage-data analysis for those years in two counties.
A second FDIC letter criticized the strategic plan submitted by Swiss Avenue State Bank in Dallas for omitting the number and amount of residential real-estate and small-business loans and qualified investments in low- and moderate-income areas.
Mr. Klaer at Valley American said his bank "entered the process blindly" and was surprised with the detail required by the regulators. The bank has worked closely with the FDIC to iron out its problems, and it expects to have a revised plan resubmitted by Sept. 1, he said. Officials with Swiss Avenue refused to comment on their plan.
The regulators' demands are too much, according a compliance officer at a bank that has submitted a plan to the Office of the Comptroller of the Currency. The banker, who did not want to be identified, said it is not realistic to pin down exact loan totals over a series of years, especially if the institution plans to acquire other banks in the near future.
"I can't go to my board and executive management and lock them into specific numbers over the next few years," he said. "We gave boundaries to shoot for, thinking that was the whole thrust of the plan."
First National Bank of South Dakota, Yankton; First National Bank of Kansas, Overland Park; Bank Midwest in Kansas City, Mo.; Citibank Nevada, Las Vegas; and Plains National Bank in Lubbock, Tex., have sent strategic plans to the Comptroller's Office.
In addition to Valley American and Swiss Avenue, the FDIC has received proposals from: Denver's Young Americans Bank, Cincinnati's Westwood Savings Bank, Boston Private Bank and Trust, and Peoples Savings Bank in Holyoke, Mass.
The Federal Reserve Board and Office of Thrift Supervision haven't received any plans.