Appeals of Material Supervisory Determinations: Guidelines
SARC-99-05 (September 13, 1999)
On September 8, 1999, the Supervision Appeals Review
Committee (“Committee”) of the Federal Deposit Insurance Corporation
(“FDIC”) considered the appeal by [Bank] (“Bank”), of the Community
Reinvestment Act (“CRA”) rating resulting from the FDIC’s examination of the
Bank on October 13, 1998.
After carefully considering the issues raised in your
appeal package dated July 2, 1999, the Committee concluded that the CRA
rating of “Needs to Improve” should be affirmed.
The Committee concluded that the Bank’s deteriorating loan
volume relative to other local institutions as well as its own capacity to
lend are not indicative of “Satisfactory” performance under the Community
Reinvestment Act. Additionally, the Committee concurs with findings
indicating that the significant reductions in both the dollar volume of
gross loans and the loan-to-deposit ratio since the last examination cannot
be attributed to local economic and/or demographic conditions, but instead
are due in large part to factors under management’s control.
This decision is considered a final supervisory
determination by the FDIC.
By direction of the Supervision Appeals Review Committee
of the Federal Deposit Insurance Corporation.