BOARD OF GOVERNORS
DIVISION OF CONSUMER
October 14, 2004
TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS:
SUBJECT: CRA Core Tables
This letter transmits guidance regarding the use of demographics and core tables used in the preparation of CRA performance evaluations (PE) which was recommended by the Federal Financial Institutions Examination Council (FFIEC). This guidance has been approved for immediate use by the System.
The inclusion of the FFIEC core tables in CRA PEs will be left to the discretion of each Reserve Bank. Reserve Banks may include all of the core tables in their large bank PEs or may elect to include only the core tables that they deem to contain the most appropriate and meaningful data to support the CRA evaluation results. Reserve Banks may also include other data tables that they have developed in the PEs or may elect to include only a narrative. No matter what format is used, the information included in the PE must be comprehensive and present the facts and data to support the evaluation results.
In addition, if the core tables are included in a PE, the tables should contain only bank and aggregate data reflecting the most recent year for which aggregate data are available. For example, if a CRA examination began on April 1, 2004 (before the 2003 aggregate data are available and assuming a two-year examination interval), the core tables would contain 2002 bank data and 2002 aggregate data. Any 2003 and 2004 loan data falling within the evaluation period would be included in the analysis as performance context, and brought forward into the performance evaluation, as appropriate. It would not be included in the core tables. As a further example, if a CRA examination were begun on July 1, 2004 , and the 2003 aggregated data was available, the core tables would contain 2003 bank data and 2003 aggregate data. Any of the bank's 2002 and 2004 loan data falling within the evaluation period would be included in the analysis as performance context but would not be in the core tables.
The FFIEC Consumer Compliance Task Force is beginning a project to review the core tables. The project team, on which Board, Reserve Bank and other Agency staff are participating, will make recommendations to the CCTF regarding whether the core tables should be retained in their current form, modified, or eliminated.If you have any questions please call the Oversight Review Examiner that is assigned to your district.
CA letters | 2004 Letters