A
bank formally appealed the management rating of 2 assigned at the
most recent safety and soundness examination. The appeal states that the
management rating is based solely on the "needs to improve" CRA
rating without sufficient consideration of overall board and
management supervision.
Discussion
The Report of
Examination stated that ''board oversight and management supervision
are satisfactory; . . . however, they did not provide adequate
oversight in complying with the requirements of CRA resulting in a
'needs to improve' rating.''
OCC Bulletin 97-1, Uniform Financial Institutions Rating
System, states that the capability and performance of management and
the board of directors is rated based upon evaluation factors which
include the level and quality of oversight and support of all
institution activities by the board and management.
Conclusion
Based on the
noted deficiencies in the bank's overall management and
administration of its CRA activities, the ombudsman concluded that
the assigned 2 management rating was
appropriate.
