| TO: | CHIEF EXECUTIVE OFFICER AND COMPLIANCE OFFICER |
| SUBJECT: | Guidelines for Strategic Plan Submissions |
The Federal Deposit Insurance Corporation (FDIC) has developed the attached guidelines for financial institutions choosing to have their Community Reinvestment Act (CRA) performance evaluated under the strategic plan option. The attachment supplements existing guidance for preparing and submitting a strategic plan to the FDIC for approval.
Under the revised CRA regulations, a financial institution may select the strategic plan approach. This method provides the institution an opportunity to tailor its CRA objectives to help meet the credit needs of its community consistent with its business strategy and operational focus. The FDIC previously provided guidance about the information to be included in a strategic plan. However, questions and areas of concern remained, particularly about developing measurable goals and appropriate performance information. The FDIC's strategic plan review process also needed clarification.
The strategic plan's required contents and the FDIC's criteria for evaluating a strategic plan are included in the FDIC's CRA regulations, 12 C.F.R. sec. 345.27. The strategic plan approach offers considerable flexibility to institutions in choosing how to measure their CRA performance. As a result, not all of the factors described in these guidelines will apply to each institution.
The attached guidelines address various issues that have arisen in the FDIC's review of strategic plan submissions since the option became available in January 1996. The FDIC believes that the lessons learned during these earlier reviews may assist institutions that are considering this alternative evaluation approach to demonstrating CRA performance. One section in the guidelines identifies specific resources from which institutions may obtain demographic, economic and related data to prepare their plans. The information sources include the FDIC and selected agency Web sites.
The FDIC recognizes that developing a viable strategic plan is labor-intensive and costly. We commit to this promise: if a financial institution expends the effort to meet the criteria outlined in this guide and in other official information sources, the FDIC will respond expeditiously with an affirmative decision.
FDIC staff members are available to help institutions develop their strategic plan submissions. For further information, please contact the appropriate Division of Compliance and Consumer Affairs regional office on the attached list.
Carmen J. Sullivan
Director
Distribution
FDIC-Supervised Banks (Commercial and Savings)
Note
Paper copies of FDIC financial institution letters may be obtained through the FDIC's Public Information Center, 801 17th Street, N.W., Room 100, Washington, D.C. 20434 (800-276-6003 or (703) 562-2200).