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
- Investment test
- Service tests
- Community development test
- Strategic plan evaluation
The testing and evaluation components may vary based on the size and type of institution being examined.
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:
- National origin
- Ethnic origin
- Marital status
- 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 institution's performance, one of five ratings is assigned:
- High 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. All institutions must maintain a copy of the public evaluation in your public information file and make the evaluation available upon request.
CRA performance is taken into account when considering applications for:
- Mergers or acquisitions
- Mobile electronic branches
- Any other DOB approval provided that there are no other offsetting financial safety and soundness or other policy considerations
Banks and credit unions subject to CRA compliance must define an assessment area(s). The DOB evaluates the institution's record of helping to meet community credit needs within their assessment area(s).
Massachusetts-chartered credit unions whose membership by-law provisions are not based on residence may use their membership as the assessment area.