CRA Performance Evaluation Reports

Branch Closing Analysis Reports

The following factors are important considerations in providing a Community Impact Study pertaining to a bank’s branch closing:

  • Convenience
    • this may be measured using different tests and different standards
      • Possible Tests or measuring sticks: Determine the branch service area in terms of Drive time or Distance to branch from surrounding area
      • Possible Standards: 5 minutes driving time or 3 miles distance (or other standards consistent with TCB branch closing policy)
  • Scope of services
    • what services does the branch to be closed provide?
    • what other bank branches are within the branch service area and what type of services do they provide?
  • Magnitude of Impact
    • this would be measured in terms of the volume of deposits outstanding within the branch to be closed (latest SOD report) in comparison to the deposits in other bank branches within the branch service area
  • Community Reinvestment Act considerations
    • What is the income class of the tract in which the branch is located?
    • Are there any low- or moderate-income census tracts within the branch service area?
    • Will the branch closing affect Assessment Area Delineation?
      • what technical CRA implications does branch closing have? (must the AA be modified pursuant to Reg BB, Section 345.41)
      • what practical implications does branch closing have? (should the AA be modified?)
  • Basic Requirements: Develop a map and tabulate data pertinent to the branch service area
    • Map the "service area" (using the test and standards to be agreed upon)
    • Map all bank branches that fall within the service area (extracted from the SOD) and portray the branch size (measured in deposits outstanding) by a "color theme"
    • Map the census tracts within the service area and portray their income class with color theme (optional: map "minority" tracts")
    • Determine scope of services (service level) offered through branch to be closed
    • Tabulate the service level (as per SOD) of branches within the service area
    • Tabulate the distribution of deposits among branches that fall within the service area and delineate market share
  • Optional Extras
    • Demographic variables - add Family Income demographics
    • CRA impact statement (comment about CRA consequences if any, in particular the Assessment Area delineation and implications for "Service Test" - this would be intended for management and not the public)
    • Minority tracts?

These general areas of concern, and the methodologies described for performing an analysis of them, are important considerations for establishing the effect of a branch closing on its Community. Together with other interests of the Bank and special concerns it may want included, an efficient and effective study can be completed. After review of this information and feedback from you and your management, we can provide you with a professionally drafted proposal.

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