Map of Assessment Area with Geographies
downtown Effingham facing eastward
Tract Code | Tract Income Level | Distressed or Under -served Tract | Tract Median Family Income % | 2023 FFIEC Est. MSA/MD non-MSA/MD Median Family Income | 2023 Est. Tract Median Family Income | 2020 Tract Median Family Income | Tract Population | Tract Minority % | Minority Population | Owner Occupied Units | 1- to 4- Family Units |
9501.00 | Upper | No | 139.70 | $82,300 | $114,973 | $96,341 | 3910 | 3.17 | 124 | 1327 | 1818 |
9502.00 | Upper | No | 154.59 | $82,300 | $127,228 | $106,607 | 5196 | 6.43 | 334 | 1651 | 2133 |
9503.00 | Middle | No | 114.98 | $82,300 | $94,629 | $79,292 | 4130 | 4.7 | 194 | 1376 | 1738 |
9504.00 | Middle | No | 84.41 | $82,300 | $64,469 | $58,214 | 3649 | 5.02 | 183 | 1310 | 1559 |
9505.00 | Upper | No | 129.14 | $82,300 | $106,282 | $89,053 | 4629 | 4.26 | 197 | 1501 | 1725 |
9506.00 | Upper | No | 123.98 | $82,300 | $102,036 | $85,500 | 5499 | 6.31 | 347 | 1811 | 2174 |
9507.00 | Middle | No | 93.42 | $82,300 | $76,885 | $64,423 | 3587 | 10.65 | 382 | 759 | 1112 |
9508.00 | Middle | No | 80.85 | $82,300 | $66,540 | $55,755 | 4068 | 13.42 | 546 | 888 | 1635 |
None
Crossroads Bank – Main Bank
2000 S. Banker Street
Effingham, IL 62401
(217) 347 – 7751
Census Tract 9508
Crossroads Bank – Keller Drive Branch
806 N. Keller Drive
Effingham, IL 62401
(217) 342 – 4422
Census Tract 9508
Geographies Served
Both locations serve all of Effingham County, Illinois
Date | 3/31/2023 | 6/30/2023 | 9/30/2023 | 12/31/2023 |
Net Loans and Leases | 129,297 | 134,326 | 133,444 | 138,649 |
Total Deposits | 189,207 | 184,984 | 181,082 | 182,868 |
Loan to Deposit Ratio | 68.34% | 72.61% | 73.69% | 75.82% |
Crossroads Bank
Hours of Operation and Services Provided
2000 South Banker and 806 North Keller Drive, Effingham, IL 62401
HOURS OF OPERATION
LOBBIES DRIVE-UPS
Mon. – Thurs. 8:30 – 4:00 7:30 – 5:00
Friday 8:30 – 5:00 7:30 – 5:30
Saturday 8:30 – 12:00 7:30 – 12:00
SERVICES PROVIDED
Deposits
Loans
Each location has a 24 hour ATM available.
Each location has drive up night deposit service.
Each location offers Safe Deposit Boxes.
Transaction fees are detailed on the Common Feature and Fees Sheet which is attached.
Trust Services are available at the 2000 S. Banker Location.
COMMON FEATURES AND FEES
Replace Lost Debit Card – $10.00
ATM cash withdrawal daily limit – $300.00 per 24 hours
ATM cash withdrawal at ATMs we do not own or operate – $3.00
Transfer funds at ATMs we do not own or operate – $3.00
Check Printing – (fee depends on style and quantity of check ordered)
Money Orders
– Customer – $3.00
– Non Customer – $5.00
– Coffee Club account holders – No Charge
Garnishments – $75.00
Levies – $75.00
The categories of transactions for which an overdraft fee may be imposed are those by any of the following means; check, in-person withdrawal, ATM withdrawal, or other electronic means.
If Overdraft amount exceeds $10.00
Overdraft Fees (paid or returned) – $30.00
Daily overdraft fee – $5.00
Automatically transfer to cover overdrafts – $5.00 per transfer
Transfers phone into Bank – $5.00 per transfer
Easy Touch Banking (phone transfers) – No Charge
NSF deposited returned fee – $10.00 per item
Personal checkbook balancing service – $20.00
Lost loan book replacement – $5.00
Night deposit bags (no charge 1st bag) – $20.00
Plain zipper bag (no charge 1st bag) – $5.00
Account activity printout – $5.00
Account research (per hour) – $25.00
Copy of statement – $5.00
Account balancing assistance (per hour) – $20.00
– Minimum – $20.00
Stop payments (all items) – $30.00
Photocopies (per page) – $0.50
Paper and Electronic Statements Fee – $5.00
Domestic wire transfers – Outgoing
– Customer – $25.00
– Noncustomer – $50.00
Domestic wire transfers – Incoming
– Customer – $10.00
– Noncustomer – $25.00
Foreign wire transfers – Outgoing
– Customer – $50.00
– Noncustomer – $75.00
Foreign wire transfers – Incoming
– Customer – $10.00
– Noncustomer – $25.00
Safe Deposit Boxes:
– 3 x 5 box – yearly rent $ 20.00
– 3 x 1O box – yearly rent $ 30.00
– 5 x 1O box – yearly rent $ 45.00
– 10 x 10 box – yearly rent $ 60.00
Drill safe deposit box actual cost plus $25.00
Safe deposit box key replacement
Please Note: You agree not to duplicate any keys provided to you pursuant to your Safety Deposit Box Lease. You will return two keys on
termination of this lease. You will notify us immediately if you lose a key and at this time you will have two options. Option #1 – Replace the
duplicated key at your cost. Option #2 – Change the lock on the box and
Collection fees:
– Customer – $ 25.00
– Non Customer – $ 25.00
Fax:
– Local cans (per page) – $1.00
– Other calls (per page) – $2,00
Monthly pay received – $250.00
Other than monthly payments – $200.00
Plus, acceptance charge – $100.00
Indemnity bonds – $10.00
Notary fee
– Customer – No Charge
– Non Customer – $2.00
Dormant Accounts:
An account Is dormant if for 182 days on DOA, or 2 years on savings, you have made no deposits or withdrawals to the account and you have had no communication with us about your account(s).
Dormant account fee:
– Checking – per statement cycle – $5.00
– Savings – per statement cycle – $5.00
We may require not less than 7 days’ notice in writing before each withdrawal from an Interest-bearing account other than a time deposit, or from any other savings account as defined by Regulation D.
Withdrawals from a time account prior to maturity or prior to any notice period may be restricted and may be subject to penalty. See our notice of penalty for early withdrawal.
Reviewed 02/2023
None
PUBLIC DISCLOSURE
October 27, 2020
COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
Crossroads Bank Certificate Number: 21486
2000 South Banker Street Effingham, Illinois 62401
Federal Deposit Insurance Corporation Division of Depositor and Consumer Protection Chicago Regional Office
300 South Riverside Plaza, Suite 1700
Chicago, Illinois 60606
This document is an evaluation of this institution’s record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, nor should it be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution.
TABLE OF CONTENTS
IN”STITUTION RATIN”G…………………………………………………………………………………………….. 1
DESCRIPTION OF IN”STITUTION………………………………………………………………………………. 2
DESCRIPTION OF ASSESSMENT AREA…………………………………………………………………….. 3
SCOPE OF EVALUATION…………………………………………………………………………………………… 5
CONCLUSIONS ON PERFORMANCE CRITERIA…………………………………………………………. 6
DISCRIMIN”ATORY OR OTHER ILLEGAL CREDIT PRACTICES REVIEW……………………. 9
APPENDICES…………………………………………………………………………………………………………… 10
SMALL BANK PERFORMANCE CRITERIA……………………………………………………………. 10
GLOSSARY…………………………………………………………………………………………………………… 11
INSTITUTION RATING
INSTITUTION’S CRA RATING: This institution is rated Satisfactory.
An institution in this group has a satisfactory record of helping to meet the credit needs of its assessment area, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.
Crossroads Bank’s (Crossroads) satisfactory Co1mnunity Reinvestment Act (CRA) performance under the lending test supp01is the overall rating. The following factors support the institution’s rating:
DESCRIPTION OF INSTITUTION
Crossroads is a $203 million bank headquartered in Effingham, Illinois (population 12,328), the county seat of Effingham County, located in the northern portion of the county. Crossroads is wholly-owned by Omni Bancorp, Inc., a one-bank holding company. The bank’s main office and one branch are within the city limits of Effingham, one in a middle-income tract and one in an upper-income tract. Automated Teller Machines (ATMs) are located at each facility, and the bank is a member of a network allowing access to surcharge-free ATM transactions in numerous locations. Crossroads is not required to report residential real estate loans for Horne Mortgage Disclosure Act (HMDA) purposes due to its location.
Crossroads offers a variety of products and services to meet the credit and deposit needs of the local area it serves. Commercial lending remains the primary focus of the institution and includes real estate-secured, operating lines, and other business purpose credit. Consumer residential lending is a secondary focus of the bank, and loan products offered include real estate loans for home purchase, refinance, and home improvement, along with lease financing for lake prope1ties and home equity lines of credit. The bank also originates long-term, fixed-rate mortgages through another institution and has agreements to facilitate government guaranteed loans through the U.S Department of Agriculture Rural Housing program. Agricultural loans are offered by the bank but are not a business focus of the institution. Finally, consumer loans for auto, boat, recreational vehicles, mobile homes, and personal purposes are also available. Credit cards are available through a third party institution. Deposit products offered include checking, savings, certificates of deposit, and a night depository. The bank offers a variety of digital products and services, including online banking, debit cards, mobile banking, and peer-to-peer transactions. Trust services are also available.
As of June 30, 2020, the bank’s total assets were $202,797,000, total securities were $52,702,000, total loans were $130,808,000, and total deposits were $165,699,000. Total assets have grown 42 percent while total loans have grown approximately 28 percent since the previous CRA evaluation in 2014. During the same time period, deposits increased by 35 percent. The table below depicts the loan portfolio as of June 30, 2020.
Loan Portfolio Distribution as of 06/30/2020 | ||
Loan Category | $(000s) | % |
Construction and Land Development | 3,439 | 2.6 |
Secured by Farmland | 3,332 | 2.6 |
Secured by 1-4 Family Residential Properties | 16,940 | 13.0 |
Secured by Multifamily (5 or more) Residential Properties | – | – |
Secured by Nonfarm Nonresidential Properties | 71,037 | 54.3 |
Total Real Estate Loans | 94,748 | 72.5 |
Agricultural Loans | 74 | 0.1 |
Commercial and Industrial Loans | 33,586 | 25.7 |
Consumer Loans | 2,384 | 1.8 |
Other Loans | 16 | <0.1 |
Total Loans | 130,808 | 100% |
Source: Reports of Condition and Income |
Crossroads has no financial or legal impediments that would inhibit its ability to meet the credit needs of its established assessment area. The bank was assigned a CRA rating of “Satisfactory” at its prior CRA evaluation dated September 18, 2014, when the FDIC used Small Bank Examination Procedures to assess the battle’s performance.
DESCRIPTION OF ASSESSMENT AREA
EFFINGHAM COUNTY
The CRA requires each financial institution to define one or more assessment areas within which its CRA performance will be evaluated. Crossroads designated one assessment area consisting of all of Effingham County, which is not considered part of a metropolitan area. The assessment area is in conformance with CRA requirements and does not arbitrarily exclude low- and moderate-income geographies.
The Department of Housing and Urban Development categorizes individual census tracts in Effingham County as low-, moderate-, middle-, or upper-income based upon the individual geography’s median family income (MFI) as a percentage of the Illinois Non-Metropolitan Statistical Area. Based on information from the 2015 American Community Survey (ACS), the bank’s assessment area was designated with four middle-income and four upper-income census tracts. This represents a small change since the last review based on the 2010 Census, when there were five middle-income tracts and three upper-income tracts; one tract in n011heastern Effingham County was reclassified as upper-income. None of the tracts in the assessment area have been categorized as distressed or underserved by the Federal Financial Institutions Examination Council (FFIEC).
Economic and Demographic Data
The bank’s assessment area is primarily rural in nature. As noted above, there are eight census tracts which make up an entire county. The upcoming table illustrates select demographic characteristics of the assessment area.
Employment opportunities in the area are centered in agricultural, services, and retail-related fields. As with most areas, the unemployment rate has risen considerably due to the COVID-19 pandemic. The average unemployment rate for 2019 was 3.3 percent for Effingham County, according to the Illinois Department of Employment Security (IDES). In June of 2020, IDES reported the unemployment rate at 11.2 percent nationally and 14.6 percent statewide. Local unemployment rates were slightly lower than state and national averages at 10.0 percent in Effingham County.
County unemployment rates have been trending down and were 7.5 percent for July 2020 and 6.8 percent for August 2020.
Demographic Information of the Assessment Area
Assessment Area: Crossroads Bank |
||||||
Demographic Characteristics | # | Low
% of# |
Moderate
% of# |
Middle
% of# |
Upper
% of# |
NA*
% of# |
Geographies (Census Tracts) | 8 | 0.0 | 0.0 | 50.0 | 50.0 | 0.0 |
Population by Geography | 34,332 | 0.0 | 0.0 | 46.2 | 53.8 | 0.0 |
Housing Units by Geography | 14,727 | 0.0 | 0.0 | 47.2 | 52.8 | 0.0 |
Owner-Occupied Units by Geography | 10,544 | 0.0 | 0.0 | 41.6 | 58.4 | 0.0 |
Occupied Rental Units by Geography | 2,786 | 0.0 | 0.0 | 68.6 | 31.4 | 0.0 |
Vacant Units by Geography | 1,397 | 0.0 | 0.0 | 46.7 | 53.3 | 0.0 |
Businesses by Geography | 2,728 | 0.0 | 0.0 | 54.0 | 46.0 | 0.0 |
Farms by Geography | 238 | 0.0 | 0.0 | 37.4 | 62.6 | 0.0 |
Family Distribution by Income Level | 8,952 | 16.3 | 15.3 | 22.7 | 45.7 | 0.0 |
Household Distribution by Income Level | 13,330 | 19.6 | 15.4 | 17.3 | 47.6 | 0.0 |
Median Family Income Non-MSAs – IL | $59,323 | Median Housing Value | $127,516 | |||
Median Gross Rent | $587 | |||||
Families Below Poverty Level | 7.5% | |||||
Source: 2015 ACS and 2019 D&B Data
Due to rounding, totals may not equal 100.0% (*) The NA category consists of geographies that have not been assigned an income classification. |
The 2019 MFI level is used to analyze home mortgage loans under the Borrower Profile criterion. The low-, moderate-, middle-, and upper-income categories are presented in the following table. These categories are based on the 2019 FFIEC-updated MFI for the Illinois Non-MSA of $64,200.
2019 Median Family Income Ranges | ||||
Median Family Incomes | Low
<50% |
Moderate 50% to <80% | Middle 80% to <120% | Upper >120% |
IL Non-MSA (64,200) | <$32,100 | $32,100 to <$51,360 | $51,360 to <$77,040 | >$77,040 |
Source: FFIEC |
Competition
The assessment area is moderately competitive in the market for financial services with a couple dominant firms in the Effingham County market, as shown in FDIC Summary of Deposits data as of June 30, 2020. Effingham County has 11 banks operating 22 offices. Of those, Crossroads has the fifth highest deposit share at 8.1 percent. The top two banks account for over 53 percent of all deposits in the county and the top four banks hold over 76 percent of all deposits. The area is competitive for lending, as well. While Crossroads does not report loans for HMDA, 120 institutions that do report for HMDA made over 1,000 home mo1igage loans in Effingham County in 2019, indicating a ve1y competitive market for home mortgage loans.
Community Contacts
As part of the evaluation process, examiners contact third parties active in the assessment area to assist in identifying the credit and community development needs. This information helps determine whether local financial institutions are responsive to these needs. It also shows what credit and community development opportunities are available.
Examiners reached out to a community contact with knowledge of the credit needs and opportunities in the area. The contact, working with an organization focused on maintaining the vitality of the community, indicated that the area has been fairly stable, though the pandemic had a big impact on unemployment. However, an area manufacturing firm and major employer is in the process of expanding. Small business development is active in the community. The contact indicated that mortgage lenders are also active and named Crossroads Bank as one of the most prominent lenders in the county. Residential real estate tends to move quickly inside Effingham, although there is less active development. Dieterich and Teutopolis are nearby towns seeing a higher degree of development for residential housing.
SCOPE OF EVALUATION
General Information
This evaluation covers the period from Crossroad’s prior performance evaluation dated September 18, 2014, conducted by FDIC using the Interagency Small Institution Examination Procedures to evaluate the bank’s CRA pe1formance. These procedures, used again at the current evaluation, focus on the bank’s lending according to the following criteria under the Lending Test:
Activities Reviewed
Battle records and management discussion revealed that the bank’s major product lines are commercial and residential home mortgage loans. These conclusions considered the bank’s business strategy and the number and dollar volume of loans originated during the evaluation period, specifically focusing on 2019 as a representative year.
Examiners evaluated the bank’s performance using small business loan and residential home mortgage loan data from January 1, 2019, to December 31, 2019. For this evaluation, the bank’s performance is more heavily weighted for small business lending, as it is the primary product by number and dollar volume. Home mortgage lending continues to be a secondary focus for the bank and comprises a large percentage of the battle’s originations, especially when considering secondary market activity. Small farm and consumer loans were not considered in the evaluation as such loans are not a product focus.
As of June 30, 2020, commercial loans represented 80 percent of the bank’s total loan portfolio by dollar volume and was the highest product by number of2019 originations. For CRA, examiners reviewed all 108 outstanding small business loans originated or renewed in 2019. The bank’s second most prevalent product based on 2019 originations is home mortgage lending at approximately $4 million. This figure includes loans originated and sold on the secondary market, which are funded by Crossroads. Examiners reviewed all 33 in-house and secondary market loans originated during 2019. While all loans were reviewed for the assessment area concentration, only those inside the assessment area were analyzed for the geographic and borrower distributions. The 2019 D&B data and 2015 ACS data provides a standard of comparison for the bank’s small business and home mortgage lending, respectively.
CONCLUSIONS ON PERFORMANCE CRITERIA
LENDING TEST
Crossroads demonstrated reasonable performance under the lending test. Borrower Profile performance primarily supports this conclusion. While not separately analyzed in this evaluation, it was noted that the battle has originated 113 loans through the Small Business Administration’s Payment Protection Program worth nearly $8.1 million in April and May of 2020; these loans help businesses keep their workforce employed during the COVID-19 crisis. This activity, which meets an identified credit need in the community is also considered in the battle’s overall Satisfactory rating.
Loan-to-Deposit Ratio
Crossroad’s net LTD ratio is reasonable given the institution’s size, financial condition, and assessment area credit needs. The bank’s most recent net LTD as of June 30, 2020, was 78.3 percent. The average net LTD ratio was 88.4 percent over the last 24 quarters from September 30, 2014, to June 30, 2020, ranging from a low of 78.3 percent as of June 30, 2020, to a high of 98.7 percent as of December 31, 2015. The ratio has been trending slightly downward throughout the review period. Both loans and deposits have grown reasonably during the review period. Deposits have grown 35.0 percent, while net loans have grown 28.4 percent, contributing to the slight downward trend.
The bank’s average and most current net LTD ratios were compared to three other banks headquartered in Effingham County and having commercial lending as a primary product focus. In terms of the average net LTD ratio, Crossroads has the second highest of the four banks. The average net LTD ratios for the other banks ranged from 66.4 percent to 93.3 percent and are reflected in the following table.
Loan-to-Deposit Ratio Comparison | ||
Bank |
Total Assets as of
6/30/2020 ($000s) |
Average Net LTD Ratio
(0/4,) |
Crossroads Bank | 202,797 | 88.4 |
Institution #1 | 79,273 | 93.3 |
Institution #2 | 273,452 | 66.4 |
Institution #3 | 422,501 | 84.0 |
Source: Reports of Condition and Income 09/30/2014 through 06/30/2020 |
Assessment Area Concentration
The bank made a majority of small business loans and home mortgage loans, by number and dollar volume, within its assessment area. The following table shows the bank’s concentration of loans inside and outside of the assessment area.
Lending Inside and Outside of the Assessment Area | ||||||||||
Loan Category |
Number of Loans |
Total # |
Dollar Amount of Loans $(000s) |
Total $(000s) |
||||||
Inside | Outside | Inside | Outside | |||||||
# | % | # | % | $ | % | $ | % | |||
Small Business | 91 | 84.3 | 17 | 15.7 | 108 | 8,773 | 81.5 | 1,993 | 18.5 | 10,766 |
Home Mortgage | 27 | 81.8 | 6 | 18.2 | 33 | 3,149 | 79.6 | 808 | 20.4 | 3,957 |
Source: Eva!uatio11 Period: 1/1/2019-12/31/2019. Bank Data |
Geographic Distribution
The assessment area does not include any low- and moderate-income geographies, and a review of the Geographic Distribution criterion would not result in meaningful conclusions. Therefore, this criterion was not evaluated. However, it was noted that the bank’s lending, for both small business and home mortgage loans, was dispersed throughout the eight census tracts in the assessment area, with no noticeable gaps in lending penetration.
Borrower Profile
The distribution of borrowers reflects reasonable penetration among businesses of different sizes and individuals of different income levels. The bank’s performance in small business loans, which carries more weight, supports this conclusion. Examiners focused on the number of small business loans and the number of businesses served as well as the number of home mortgage loans to low and moderate-income borrowers because the number of loans is a better indicator of the number of businesses and individuals served.
Small Business Loans
The distribution of small business loans reflects reasonable penetration among businesses of different sizes. As mentioned, the level of lending to businesses of different sizes is compared to the assessment area concentration of businesses by revenue level, as reported by D&B. As shown in the following table, the bank originated 53.8 percent of small business loans to businesses with
$1 million or less in gross annual revenues, which lags the percentage of businesses reporting revenues in that range by just over 20 percent. However, it’s also useful to look at the number of businesses served, as some businesses may obtain multiple smaller loans. The bank’s 91 loans were originated to 47 different entities. Of those, 35 borrowers (74.5 percent) of them had gross annual revenues of $1 million or less, closely approximating the D&B data.
Distribution of Small Business Loans by Gross Annual Revenue Category | |||||
Gross Revenue Level | % of Businesses | # | % | $(000s) | % |
:S$1,000,000 | 76.1 | 49 | 53.8 | 5,628 | 64.2 |
>$1,000,000 | 7.8 | 42 | 46.2 | 3,145 | 35.8 |
Revenue Not Available | 16.1 | 0 | — | 0 | — |
Total | 100.0 | 91 | 100% | 8,773 | 100% |
Source: 2019 D&B Data, Bank Data.
Due to rounding, totals may not equal I00.0% |
Home Mortgage Loans
The distribution of borrowers reflects excellent penetration among individuals of different income levels, including low- and moderate-income borrowers. The bank’s record with regard to low income borrowers supports this conclusion. Examiners focused on the comparison to demographic data for the assessment area.
Home mortgage lending to low-income borrowers at 22.2 percent is excellent when compared to the
16.3 percent of families in the assessment area designated as low-income. The performance is even stronger when considering the adjusted demographic. Adjusted demographic data takes the 16.3 percent of families in the assessment area that are low-income and takes into account families living below the poverty level of 7.5 percent. Families living below the poverty level are often unable to financially qualify for home mortgage credit. As a result, comparing the bank’s performance to the adjusted number of 8.8 percent is more indicative of its lending performance.
Also exceeding assessment area demographics, home mortgage lending to moderate-income borrowers at 18.5 percent is reasonable when compared to assessment area demographics at 15.3 percent of moderate-income families. In total, over 40 percent of the bank’s home mortgage lending was to low- and moderate-income borrowers, exceeding the representation in the assessment area by 9.1 percent. The following table shows the bank’s lending to borrowers of varying income levels.
Distribution of Home Mortgage Loans by Borrower Income Level | |||||
Borrower Income Level | % of Families | # | % | $(000s) | % |
Low | 16,3 | 6 | 22.2 | 460 | 14,6 |
Moderate | 15.3 | 5 | 18,5 | 266 | 8.4 |
Middle | 22,7 | 8 | 29.6 | 778 | 24,7 |
Upper | 45.7 | 8 | 29.6 | 1,645 | 52.2 |
Total | 100.0 | 27 | 100% | 3,149 | 100% |
Source: 2015 ACS; Bank Data
Due to rounding, totals may 1101 equal 100.0% |
Response to Complaints
The bank did not receive any CRA-related complaints since the previous evaluation; therefore, this criterion did not affect the overall rating of the institution.
DISCRIMINATORY OR OTHER ILLEGAL CREDIT PRACTICES REVIEW
Examiners did not identify any evidence of discriminatory or other illegal credit practices; therefore, this consideration did not affect the institution’s overall CRA rating.
APPENDICES
SMALL BANK PERFORMANCE CRITERIA
Lending Test
The Lending Test evaluates the bank’s record of helping to meet the credit needs of its assessment area(s) by considering the following criteria:
GLOSSARY
Aggregate Lending: The number of loans originated and purchased by all rep01iing lenders in specified income categories as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area.
Area Median Income: The median family income for the MSA, if a person or geography is located in an MSA; or the statewide nonmetropolitan median family income, if a person or geography is located outside an MSA.
Assessment Area: A geographic area delineated by the bank under the requirements of the Community Reinvestment Act.
Census Tract: A small, relatively permanent statistical subdivision of a county or equivalent entity. The primary purpose of census tracts is to provide a stable set of geographic units for the presentation of statistical data. Census tracts generally have a population size between 1,200 and 8,000 people, with an optimum size of 4,000 people. Census tract boundaries generally follow visible and identifiable features, but they may follow nonvisible legal boundaries in some instances. State and county boundaries always are census tract boundaries.
Combined Statistical Area (CSA): A combination of several adjacent metropolitan statistical areas or micropolitan statistical areas or a mix of the two, which are linked by economic ties.
Consumer Loan(s): A loan(s) to one or more individuals for household, family, or other personal expenditures. A consumer loan does not include a home mortgage, small business, or small farm loan. This definition includes the following categories: motor vehicle loans, credit card loans, home equity loans, other secured consumer loans, and other unsecured consumer loans.
Core Based Statistical Area (CBSA): The county or counties or equivalent entities associated with at least one core (urbanized area or urban cluster) of at least 10,000 population, plus adjacent counties having a high degree of social and economic integration with the core as measured through commuting ties with the counties associated with the core. Metropolitan and Micropolitan Statistical Areas are the two categories of CBSAs.
Family: Includes a householder and one or more other persons living in the same household who are related to the householder by birth, marriage, or adoption. The number of family households always equals the number of families; however, a family household may also include non-relatives living with the family. Families are classified by type as either a married-couple family or other family. Other family is further classified into “male householder” (a family with a male householder and no wife present) or “female householder” (a family with a female householder and no husband present).
FFIEC-Estimated Income Data: The Federal Financial Institutions Examination Council (FFIEC) issues annual estimates which update median family income from the metropolitan and nonmetropolitan areas. The FFIEC uses American Community Survey data and factors in
information from other sources to arrive at an annual estimate that more closely reflects current economic conditions.
Full-Scope Review: A full-scope review is accomplished when examiners complete all applicable interagency examination procedures for an assessment area. Performance under applicable tests is analyzed considering performance context, quantitative factors (e.g., geographic distribution, borrower profile, and total number and dollar amount of investments), and qualitative factors (e.g., innovativeness, complexity, and responsiveness).
Geography: A census tract delineated by the United States Bureau of the Census in the most recent decennial census.
Home Mortgage Disclosure Act (HMDA): The statute that requires certain mortgage lenders that do business or have banking offices in a metropolitan statistical area to file annual summary reports of their mortgage lending activity. The repo1is include such data as the race, gender, and the income of applicants; the amount of loan requested; and the disposition of the application (approved, denied, and withdrawn).
Home Mortgage Loans: Includes closed-end m01igage loans or open-end line of credits as defined in the HMDA regulation that are not an excluded transaction per the HMDA regulation.
Housing Unit: Includes a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied as separate living quarters.
Limited-Scope Review: A limited scope review is accomplished when examiners do not complete all applicable interagency examination procedures for an assessment area.
Performance under applicable tests is often analyzed using only quantitative factors (e.g., geographic distribution, borrower profile, total number and dollar amount of investments, and branch distribution).
Low-Income: Individual income that is less than 50 percent of the area median income, or a median family income that is less than 50 percent in the case of a geography.
Market Share: The number of loans originated and purchased by the institution as a percentage of the aggregate number of loans originated and purchased by all rep01iing lenders in the metropolitan area/assessment area.
Median Income: The median income divides the income distribution into two equal patis, one having incomes above the median and other having incomes below the median.
Metropolitan Division (MD): A county or group of counties within a CBSA that contain(s) an urbanized area with a population of at least 2.5 million. A MD is one or more main/secondary counties representing an employment center or centers, plus adjacent counties associated with the main/secondary county or counties through commuting ties.
Metropolitan Statistical Area (MSA): CBSA associated with at least one urbanized area having a population of at least 50,000. The MSA comprises the central county or counties or equivalent entities containing the core, plus adjacent outlying counties having a high degree of social and economic integration with the central county or counties as measured through commuting.
Middle-Income: Individual income that is at least 80 percent and less than 120 percent of the area median income, or a median family income that is at least 80 and less than 120 percent in the case of a geography.
Moderate-Income: Individual income that is at least 50 percent and less than 80 percent of the area median income, or a median family income that is at least 50 and less than 80 percent in the case of a geography.
Multi-family: Refers to a residential structure that contains five or more units.
Nonmetropolitan Area (also known as non-MSA): All areas outside of metropolitan areas. The definition of nonmetropolitan area is not consistent with the definition of rural areas. Urban and rural classifications cut across the other hierarchies. For example, there is generally urban and rural territory within metropolitan and nonmetropolitan areas.
Owner-Occupied Units: Includes units occupied by the owner or co-owner, even if the unit has not been fully paid for or is mortgaged.
Rated Area: A rated area is a state or multistate metropolitan area. For an institution with domestic branches in only one state, the institution’s CRA rating would be the state rating. If an institution maintains domestic branches in more than one state, the institution will receive a rating for each state in which those branches are located. If an institution maintains domestic branches in two or more states within a multistate metropolitan area, the instih1tion will receive a rating for the multistate metropolitan area.
Rural Area: Territories, populations, and housing units that are not classified as urban.
Small Business Loan: A loan included in “loans to small businesses” as defined in the Consolidated Report of Condition and Income (Call Report). These loans have original amounts of
$1 million or less and are either secured by nonfarm nonresidential prope1iies or are classified as commercial and industrial loans.
Small Farm Loan: A loan included in “loans to small farms” as defined in the instructions for preparation of the Consolidated Report of Condition and Income (Call Report). These loans have original amounts of $500,000 or less and are either secured by farmland, including farm residential and other improvements, or are classified as loans to finance agricultural production and other loans to farmers.
Upper-Income: Individual income that is 120 percent or more of the area median income, or a median family income that is 120 percent or more in the case of a geography.
Urban Area: All territories, populations, and housing units in urbanized areas and in places of 2,500 or more persons outside urbanized areas. More specifically, “urban” consists of territory, persons, and housing units in places of 2,500 or more persons incorporated as cities, villages, boroughs (except in Alaska and New York), and towns (except in the New England states, New York, and Wisconsin).
“Urban” excludes the real portions of “extended cities”; census designated place of2,500 or more persons; and other territory, incorporated or unincorporated, including in urbanized areas.