WASHINGTON - While regulators are still crafting new examinations for the Community Reinvestment Act, agency officials explained last week how they intend to evaluate large banks during the next 20 months.
Between now and July 1, 1997 - when the new CRA rules take effect for banks with more than $250 million in assets - examiners will focus on five of the existing 12 assessment factors.
Stephen M. Cross, deputy comptroller for compliance management, said the five factors emphasized during the transition period will be: geographic distribution of loans, number of home mortgage and small-business loans, participation in government loan programs, participation in community development activities, and the bank's record of opening and closing branches.
"We'll be conducting the exams using the old rules, but we can't ignore what's going on," said Mr. Cross. "We'll try not to impose burdens by looking at processes more than we need to."
Mr. Cross and representatives from the three other agencies participated in a televised conference last Friday to unveil the details of the new CRA exam procedures. The telecast was viewed by more than 2,600 bankers and examiners at approximately 140 sites around the country.
Several other wrinkles in the exam procedures were revealed:
*If a small bank goes over the $250 million-asset threshold, through acquisition or growth, it will not have to begin collecting data or be examined under the large bank rules until the next calendar year.
*Regulators said small banks should remove their current CRA statements and post new notices as of Jan. 1, 1996, the date the new CRA rules take effect for small banks. New public files should be handled the same way.
*Regulators will go over a bank's loan data with a fine-toothed comb looking for errors, though exactly how examiners will test the data has not been determined yet.
That's exactly what's frustrating bankers. People watching the telecast here said they were disappointed that the regulators didn't provide more specifics about the new exams.
Francis X. Grady, a partner at Grady and Associates, Cleveland, said he learned nothing new from the teleconference.
"You had to go to make sure that you didn't miss anything," Mr. Grady said, "but nothing really new came out of it.
The strategic plan option continues to be one of the biggest sources of questions. Part of the four-and-a-half-hour conference was devoted to a sales pitch for the strategic plan, but bankers complained that there wasn't enough detail about how to develop the plan.
Thus, many in the industry remain timid about the strategic plan and somewhat confused about exactly what it entails.
Glenn E. Loney, community affairs officer with the Federal Reserve Board, said the certainty of results inherent in the strategic plan made it worth taking a chance on.
"Examiners will check to see if you met your established goals," he said. "If you met your goals, end of discussion."
If goals are not reached, examiners will determine whether they were "substantially met," he said. How close the bank came to meeting its goals would be determined by assessing the relative importance of the unreached goals, and their impact on low- and moderate-income people and geographies, according to Mr. Loney.
But it's not even clear what makes an acceptable goal. According to Mr. Loney, proposed goals would be judged using these criteria: the extent of lending activity involved, the amount and innovative qualities of qualified investments, and the availability and effectiveness of services.
For some, the guidelines seemed too vague.
"I was a little disappointed in that there just weren't enough specifics," said Kate Barr, senior vice president and compliance officer at Riverside Bank, Minneapolis. "They didn't give us any concrete idea of how it should look."