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.
.@QuestSoft’s Report Reveals CRA Exam Analysis and Trends Over the Past 10 Years
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.