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<br />agencies to evaluate CRA performance. The results of these examination are <br />considered when an institution seeks approval for expansion and acquisition <br />plans. Mr. Sullivan noted that the overall effectiveness and enforcement of <br />CRA has been below expectations. However, recent changes in CRA have provid- <br />ed a simplified rating system and public disclosure of examination results, <br />resulting in renewed interest in CRA as a method of encouraging community- <br />wide lending and reinvestment. <br /> <br />Mr. Sullivan reviewed the performance categories and assessment factors for <br />CRA which are included in the appendix of the report entitled "Increasing <br />Community Reinvestment: A Practical Approach" included in the council's <br />agenda packet. He said that the institution's overall performance rating is <br />based on a review of the following areas: <br /> <br />1) Efforts to ascertain community credit needs; <br />2) marketing and types of credit extended; <br />3) geographic distribution and record of opening and closing offices; <br />4) discrimination and other illegal practices; and <br />5) community development. <br /> <br />Mr. Sullivan provided a brief overview of the types of activities in which <br />institutions could become involved to enhance their performance rating. <br />These activities include, but are not limited to, participating in govern- <br />ment-sponsored loan guarantee programs; demonstrating an active involvement <br />in community credit issues; and participating and investing in community <br />development projects and programs designed to enhance borrowing capacity. <br /> <br />~ Mr. Sullivan briefly described activities of financial institutions in other <br />areas used to improve their CRA ratings. He said that banks and financial <br />institutions have become involved in development corporations, involving a <br />mix of public, private, and non-profit institutions. In addition, some intu- <br />itions have become involved in bank-sponsored loan consortia which provide <br />the advantages of pooled resources and shared risks among institutions. <br />Also, communities have instituted CRA programs such as lender commitment <br />programs and research and intervention efforts. <br /> <br />e <br /> <br />e <br /> <br />Mr. Sullivan said that one way to acknowledge an institution that makes a <br />good effort toward community reinvestment is by placing a letter in an insti- <br />tution's public file. This file is reviewed by the Federal government in <br />its investigation of CRA compliance. <br /> <br />Mr. Sullivan noted that Pittsburg, Pennsylvania, has a unique CRA program <br />that has been very successful in that area. He explained that the City of <br />Pittsburgh has developed its own CRA rating system with stringent criteria <br />and a linked deposit program with the local banks. Mr. Sullivan noted that <br />in formulating such criteria, every effort must be made to ensure the fair- <br />ness of the criteria. <br /> <br />Mr. Sullivan briefly described a work plan model for CRA program development. <br />The first step involves the formation of a task team to review community <br />credit needs. The next step is to seek the active participation of community <br /> <br />MINUTES--Eugene City Council <br /> <br />May 8, 1991 <br /> <br />Page 5 <br />