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As part of its responsibility for supervising and regulating the CRA activities of national banks,
the Office of the Comptroller of the Currency, from time to time, issues letters interpreting the
Community Reinvestment Act. Those letters are published in the monthly compilation Interpretations
and Actions, and are available to read and/or download by selecting from the list below. Each letter
is available in HTML by clicking on the letter number, in WordPerfect 6.1 for Windows format by
clicking on the WP following the description, or in Microsoft Word 97 format by clicking on the WORD
following the description.
About the Presentation
The letters have been redacted to remove business and other information that should be kept confidential, often including the names of the inquirer. Such redactions are indicated by brackets ([ ]). Similarly, letters in HTML format incorporate footnotes into the text. Those incorporations are indicated by a smaller type size and <NOTE: before the footnote text and > after it.
About the Content
These letters reflect the views of the Comptroller's legal staff and are subject to change.
Letters Available
Interpretive
Letter No. |
Letter
Date |
Topic |
|
| 820 |
January 27, 1998 |
Letter states that financial institutions should collect and report (if required), the gross
annual revenue or income of a small business or consumer borrower, rather than the adjusted gross
annual revenue or income of the borrower. |
|
| 810 |
December 12, 1997 |
Letter states that financial institutions may receive favorable CRA credit for investing in a
middle income housing down-payment assistance program if the investment is a "qualified investment"
under the CRA regulation. |
|
| 809 |
November 20, 1997 |
Letter provides guidance about data collection requirements and performance standards for
small wholesale institutions under the Community Reinvestment Act (CRA) regulations. |
|
| 802 |
September 17, 1997 |
Letter states that a financial institution's activities in connection with a program offering
a financial services education curriculum for high school students would receive favorable CRA
consideration if the students participating in the course were low- and moderate- income. |
|
| 800 |
September 11, 1997 |
Interagency CRA interpretive letter addressing three issues in connection with financial
institutions' investments in pooled national community development funds. |
|
| 799 |
September 3, 1997 |
Letter provides broad applicable guidance pertaining to the treatment under the CRA regulations
of financial institutions' participation in funds, such as the one described, which would invest
in certain businesses. |
|
| 798 |
September 3, 1997 |
Letter states that if an unrated security is held, accounted for, and reported for CRA purposes
by a financial institution as a loan or loan participation, the institution may have it considered
under the CRA regulations' lending test. |
|
| 797 |
September 2, 1997 |
Letter provides broadly applicable guidance about how examiners would evaluate a financial
institution's investment in notes of a fund established to improve business and commercial
opportunity for economically disadvantaged individuals or business. |
|
| 795 |
August 14, 1997 |
Letter discusses whether examiners would favorably consider under CRA the activities of two
community development corporations that the bank intends to form. |
|
| 794 (REV) |
August 11, 1997 |
Interagency CRA letter stating that an investment in an MBS bond that is specifically
tailored to an institution's CRA requirements appears to be a "qualified investment" under the
CRA regulations. [footnote # 2 has been revised.] |
|
| 793 |
August 5, 1997 |
Letter discusses how an examiner would determine whether loans for renovation of a housing
project would receive favorable consideration under the CRA regulations. |
|
| 792 |
July 25, 1997 |
Letter discusses whether an institution that invests in an entity that supports small
businesses in the institutions's assessment area receive positive consideration for making a
"qualified investment" under the CRA regulations. |
|
| 787 |
June 10, 1997 |
clarification of "qualified investment" under the CRA
regulations. |
|
| 784 |
May 30, 1997 |
treatment of equity-equivalent investments under the lending
test. |
|
| 783 |
May 22, 1997 |
CRA consideration for contributions to the small business loan fund and contributions to the
loan fund's operating expenses. |
|
| 775 |
November 4, 1996 |
CRA consideration for participation in community service programs offered
by a financial company. |
|
| 774 |
October 2, 1996 |
CRA treatment of mortgage loans to fund part of a program to provide affordable
housing. |
|
| 773 |
March 14, 1997 |
CRA status of a program to provide loans and financial management training to
low-income parents. |
|
| 765 |
December 24, 1996 |
Loans for church premises that qualify as small business or community development
loans. |
|
| 764 |
December 23, 1996 |
purchases of obligations of certain special purpose
vehicles backed by affordable housing mortgages. |
|
| 763 |
December 23, 1996 |
investment in umbrella partnership real estate investment trust to engage in community development activities. |
|
| 762 |
December 11, 1996 |
CRA regulations and certain trade financing services. |
|
| 750 |
September 23, 1996 |
investment in a housing referral and assistance organization for low- and moderate-income
individuals. |
|
| 746 |
September 9, 1996 |
participation in a revolving loan program (RLP) |
|
| 729 |
June 14, 1996 |
collecting and reporting locations of loans to borowers with non-geographic addresses |
|
| 728 |
June 18, 1996 |
treatment of the FMA "Direct Deposit Too" program |
|
| 727 |
June 26, 1996 |
treatment of "equity equivalent" instruments offered by a non-profit lender |
|
| 726 |
June 21, 1996 |
application of CRA regulations to support of microenterprise lending programs. |
|
| 723 |
April 15, 1996 |
purchase of debentures of a specialized small business investment company |
|
| 715 |
April 2, 1996 |
investment in a fund supporting affordable housing, education, & small business |
|
| 714 |
March 25, 1996 |
investments in CDBs |
|
| 713 |
March 4, 1996 |
student loans and the CRA |
|
| 710 |
February 21, 1996 |
lending by an affiliate |
|
| 709(Rev) |
June 14, 1996 |
investment in a community development bank (replaces
709) |
|
| 708 |
February 16, 1996 |
loans to a fund that provides mortgage insurance for affordable housing |
|
| 702 |
February 13, 1996 |
investment in a UIT holding mortgage securities |
|
| 701 |
January 31, 1996 |
grants to a clinic providing free health care for low-income patients |
|
| 673 |
June 26, 1995 |
investments in a bank with a community development focus |
|
| 672 |
June 29, 1995 |
investments in a company that finances affordable housing |
|
| 665 |
May 31, 1995 |
grants to a non-profit educational foundation |
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