• Different CRA Strategies for Different Goals

• New CRA Strategies for Banks

• New CRA Strategies for Community Groups

• New CRA Strategies for Regulators

• The Myopic CRA Strategist

• Revisiting the CRA Triangle

• How "Friendly" Regulators Distort the CRA Triangle

• The Best and Worst of the CRA Triangle

• The Friends of CRA

• The Enemies of CRA

• New Records Set in the Making of the New CRA

• Timing is Everything

• The New, Newer, and Newest CRA

• Strategic Options Under the New CRA

• A CRA Exemption -- The Ultimate New CRA Loophole

• Regulatory CRA Wars: FED vs. DOJ

• Regulatory CRA Wars: FED vs. OCC

• Natural Extension of Community Reinvestment Performance

• The Author's Involvement in the Development of the New CRA

• Different CRA Strategies for Different Goals

• Botched CRA Grade Deflation at the OTS' Central Region

• What We Have Learned from Six Years of Public CRA Ratings

• The Best and Worst CRA States

• Current Findings on the Five Worst CRA States

• Current Findings on the Five Best CRA States

• Identifying the Best CRA Banks

• Appeals of Old and New CRA Ratings

• CRA Enforcement as an Oxymoron

• Examining the Enforcers

• Rating the Regulators on their FOIA Friendliness

• CRA Application Denials

• Job Description for a Friendly Regulator

• CRA Protests and Denials

• Formal and Informal Enforcement Actions

• Disclosed Violations in CRA Exams

• Referrals to the DOJ -- The "Regulator from Hell"

• DOL Testing for "Fair Hiring"

• Alternative CRA Strategies for Megamergers

• Recommended "C&N" Megamerger Strategies for the CRA Triangle

• Possible Discrimination in Banking Colonies and Interstate Banking

• Three C&N Comments on Three Largest Megamergers

• Analyses of First Union's Alleged Fee Discrimination in Florida

• Specific Fee Comparisons Documenting Fee Discrimination by First Union

• Evaluation of an Interstate Fee Discrimination Strategy

• Apparent Output Discrimination in Florida by First Union

• The FED and OCC Ignore Alleged Interstate Fee and Output Discrimination

• Excessive CRA and Fair Lending Enforcement Strategy

• Record DOJ Settlement Keeps Getting Bigger!

• The Road to Regulatory Hell

• CRA Hell: Three Exams, Two Ratings, and One Appeal

• Sensationalism at The Washington Post

• The First CRA Exam That Wasn't

• Chevy Chases Second and Third CRA Exams

• Independent Assessment of the Chevy Chase CRA Exam

• Assessment of What was in the Chevy Chase PE

• Assessment of What was NOT in the Chevy Chase PE

• Determination of "True" CRA Rating

• Appeal Upholds Examiners' Rating

• DOJ Dreams Up New Marketing Theory of Discrimination

• DOJ Makes its Case

• The Author's Past Consulting Work with Both DOJ and Chevy Chase Bank

• Independent Study Shows Best Branching Record in African-American Communities

• Why DOJ Would Have Lost the Chevy Chase Case

• Why DOJ Wouldn't Drop the Chevy Chase Case

• Life in Regulatory Hell

• The Many Problems of Our Inner Cities

• Existing Alternatives to Inner-City Banking are Unsatisfactory

• Why Our Inner Cities Need Real Branches with Real People

• Alternative Methods of Bringing Existing Banks to Inner Cities

• Shared Delivery Systems are Increasingly Common in Other Industries

• Shared Financial Institution Delivery Systems

• Two Types of Shared Branches

• The Evolution of the Shared Branch

• How the Shared Branch Works

• The Feasibility of the Shared Branch Concept

• Implementation of a Shared Branch Strategy

• A Dissenting and Protesting View on the Shared Branch

• Overtown's Good News, Bad News, Ironies, and Lessons

• Conclusion: Where Will the First Shared Bank Branch be Located?

• The New CRA Library

• Scheduling and Disclosure of New CRA Exams

• Community Contact Strategies

• Understanding the Loan-To-Deposit Ratio

• Census Geographies in the New CRA

• The LMI Focal Point of the New CRA

• LMI Data for the New CRA

• HMDA and the New CRA

• Small Business and Farm Data Under the New CRA

219

• Multiple Levels of Analysis of Small Bank New CRA Strategies

• 80-20 Rule Works for Small Banks Too

• Previous Research on Small Bank CRA Performance

• IBAA Succeeds with a Separate and Diluted New CRA Standard

• OCC's Unpublished Examiner Guidelines

• Small Bank Ratings Matrix

• Four Key Ratios for the Streamlined Small Bank Exam

• Performance Level Ratings Matrix

• Relevant Benchmarks and Comps

• Summary of Small Bank Exam Procedure

• Method of Present Analysis of Small Bank Exams

• Examiner Sampling Procedures

• New CRA Ratings Analysis of Small Bank Exams

• PE Quality and Quantity

• Fair Lending Violations Under the New CRA

• The "Old" CRA Spirit Lives On!

• Complaints Under the New CRA

• Community Contacts Infrequent and Inconsistent

• Optional Investment and Service Tests

259

• Performance Test Ratios in the Small Bank Exam

• Individual Performance Test Benchmarks

• Test 1 -- LTD Ratio Analysis

• Test 2 -- AA Concentration Ratio Analysis

• Test 3 -- LMI Borrower Ratio Analysis

• Test 4 -- LMI Geography Ratio Analysis

299

• Previous CRA Research on Grade Inflation

• New Grade Inflation Methodology for a New CRA

• Inflation Analysis Methodology

• CRA Grade Deflation

• Inflation in Performance Test Ratings

• Evaluating Overall Rating Inflation Based on Regulatory Guidelines

• Evaluating Overall Rating Inflation Based on the Analysis of Individual Test Inflation

• The Worst CRA Examiners in America

• The Worst CRA Exams in America

338

• Using Inflation Analysis to Evaluate New CRA Research

340

• Results of Regression Analysis of Small Bank Exams

343

355

• Large Banks Held to a Larger Standard

• Large Retail Bank Rating Matrices

• Who Opted in Early Under the New CRA?

• New CRA Ratings

• Why Did Banks Opt in Early Under the New CRA?

• New CRA Data Availability Problems

• New CRA Exam Procedures

• Overview of Banks Opting in Early Under the New CRA

• Method of Analysis of the Lending Test

• Results of Analysis of the Lending Test

• Method of Analysis of the Investment Test

• Results of Analysis of the Investment Test

• Method of Analysis of the Service Test

• Results of Analysis of the Service Test

• Summary of Inflation Analysis of Large Retail Bank Exams

421

• Need for a Special CRA Test for Special Purpose Banks

• New Subjectivity with the New CD Test

• Who Applied for Special Purpose Bank Designations?

• Limited Purpose vs. Wholesale Banks

• Processing Special Purpose Banks Requests at the FDIC vs. OCC

• Processing Special Purpose Bank Requests at the FED and OTS

• The "International Bank Loophole"

• Wholesale Bank Designation by OCC Saves Bank From Likely NI Rating

• Unwritten Rules for Special Purpose Banks?

• FDIC vs. OCC Disparate Treatment of Nearly Identical LPB Applications

• A CRA Greek Tragedy Averted

• Lack of Information on Two OTS Denials

• Bronx Community Group Protests Three LPB and WB Designations

• Overview of Banks Analyzed in the CD Test

• Method of Analysis of the CD Test

• Results of Analysis of the CD Test

• Summary of Inflation Analysis of Special Purpose Bank Exams

475

• Whose Idea was This, Anyway?

• How Strategic Plans Differ from Other New CRA Exam Procedures

• Bankers Vote on the Least Attractive New CRA Exam Procedure

• Who Submitted Strategic Plans?

• Why Banks Submitted Strategic Plans

• Withdrawn Strategic Plans

• Why 99.7% of Banks and Thrifts Did Not Submit Strategic Plans

• Citibank's CRA Strategic Plan Slipups

• Northern Trust's "Most Favored Bank" Status at the FED Helps First SP Approval

• The FED's Plans to Allocate Credit in Ohio and West Virginia

• The FED Finally Gets Something Right on CRA

• FDIC Pokes Credit Allocation Holes in Swiss Avenue State Bank's Plan

• OCC's Double Standard in a Tale of Two (Kansas) Cities

• Household Bank Uses Strategic Plan to "Beat" the New CRA

• Method of Analysis of Strategic Plans

• Results of Analysis of Strategic Plans

• Potential for Grade Inflation With Strategic Plans

• GAO Criticizes Regulators' Own Strategic Plans!

545

• Introduction

• Major Conclusions on the New CRA

• Major Recommendations for the New CRA

• Recommended Strategies for Small Bank Exams

• Recommended Strategies for Large Retail Bank Exams

• Recommended Strategies for Limited Purpose and Wholesale Bank Exams

• Recommended Strategies for Strategic Plans

• Top Ten New CRA Mistakes by Banks

• Top Ten New CRA Mistakes by Community Groups

• Top Ten New CRA Mistakes by Regulators

569

• Appendix 1: CRP Proposals for CRA Reform

• Appendix 2: CRA Cost/Benefit Matrix

• Appendix 3: FDIC Regions

• Appendix 4: FED Districts

• Appendix 5: OCC Districts

• Appendix 6: OTS Regions

• Appendix 7: LMI Median Family Income Data for MSAs and Nonmetropolitan Portions of States for 1990 and 1996

• Appendix 8: Financial Institutions Participating in the Department of the Treasury's Minority Bank Deposit Program as of November 14, 1997

• Appendix 9: Glossary of CRA Acronyms

597