Examination process
Examinations include an evaluation for CRA compliance, and for compliance with the Equal Credit Opportunity Act (ECOA), the Home Mortgage Disclosure Act (HMDA), and other consumer protection and fair lending laws and regulations.
The DOB uses certain performance tests and standards to evaluate CRA performance. These include:
- Lending test
- Service test
- Investment test (optional)
The DOB also examines for evidence of discriminatory lending practices. Through this fair lending examination process the DOB evaluates whether credit applicants were treated differently than other applicants due to:
- Race
- Color
- Religion
- National origin
- Ethnic origin
- Sex
- Marital status
- Age
- Sexual orientation
- Physical impairment
- Source of income (all or part of an applicant's income comes from a public assistance program)
- Property location
Ratings and public evaluations
Based on your CRA examination performance, one of five ratings is assigned:
- Outstanding
- High Satisfactory
- Satisfactory
- Needs to Improve
- Substantial Noncompliance
These ratings are public information. A public evaluation is issued after the exam is complete. A public evaluation provides a narrative description of the institution's CRA performance. Institutions must maintain a copy of the public evaluation in a public information file and make the evaluation available upon request.
Assessment Area
The Commonwealth of Massachusetts is the assessment area for mortgage lenders. Mortgage lenders may request a different assessment area in Massachusetts. The DOB evaluates the institution's record of helping to meet community mortgage loan credit needs within the assessment area(s).