QuestSoft Corporation, the nation’s leading provider of automated mortgage compliance software, has completed a study reviewing 14,765 Community Reinvestment Act (CRA) performance evaluations conducted from 2010 to 2020 involving large, intermediate, and small institution exams from the OCC, FRB, FDIC, and OTS.
The results show that, on average, large institutions were more than twice as likely to receive an “Outstanding” rating when compared to intermediate-small institutions — and were more than three times as likely to receive an “Outstanding” rating compared to small institutions.
However, the percentage of large institutions receiving the top rating in 2020 is 3.67% lower than the 10-year average, and over 10% lower than 2019. In addition, no large institutions received a “Needs to Improve” or “Substantial Non-Compliance” rating in 2019 or 2020.
A majority of intermediate-small institutions received a “Satisfactory” rating with a marginally higher incidence of “Needs to Improve” ratings over other institutions. The number of intermediate-small institutions receiving an “Outstanding” rating in 2020 is marginally higher than in 2015 — which was the 10-year low. However, there is a significant increase in the percentage of intermediate-small institutions receiving a “Needs to Improve” rating in 2020.
Additionally, the study shows a substantial majority of small institutions received “Satisfactory” ratings with substantially lower percentages of “Outstanding” ratings. While low, small institutions were the most likely to receive a rating of “Substantial Non-Compliance”.
The number of small institutions that have received an “Outstanding” rating in 2020 is more than three times lower than in 2019, and more than two times lower than the 10-year average.
Leonard Ryan, president of QuestSoft, feels that all institutions can use this information to evaluate their current CRA compliance: “With the OCC [Office of the Comptroller of the Currency] going at it alone on CRA reform, it is evident that there will be a change in approach across agencies. It is now more important than ever to be focused on regulatory examination outcomes.”
Although 2020 exam results are limited to only a few months, the percentage of institutions that have received an “Outstanding” rating is lower than the prior four years, while “Needs to Improve” ratings have increased for intermediate-small institutions. The data suggests that current examination benchmarks and examiner focus may be shifting.
While some lawmakers have criticized CRA for being too easy on institutions, the data shows earning an “Outstanding” rating is an exceptional accomplishment.
Details of the full report can be found at https://questsoft.com/news/e-library/e-books/analysis-of-cra-performance-ratings
QuestSoft Corporation is the leading provider of comprehensive compliance software and services for the mortgage, bank and credit union industries. QuestSoft offers HMDA processing and reporting, CRA and fair lending compliance analytics, data management and software design expertise, enabling more than 2,500 customers to simplify and speed the collection, analysis and reporting of key lending data. For more information, call 800-575-4632, ext. 1, or visit www.questsoft.com.