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OCC CRA Exam Results

About every three years, our regulator, the Office of the Comptroller of the Currency (OCC), examines the bank's performance under the Community Reinvestment Act (CRA). The OCC reviews the bank's lending, investments, and services to ensure we are meeting the banking and credit needs of their communities -- with emphasis on low- and moderate-income communities.

At the conclusion of its evaluation, the OCC rates the bank's CRA performance as "outstanding", "satisfactory", "needs to improve", or "substantial noncompliance". Union Bank earned an "Outstanding" rating in its most recent CRA exam. This rating is based on:
  • Bank size, financial condition, and economic climate 
  • U.S. census data, available housing, and housing costs in the bank's market area
  • Past CRA performance, CRA performance of peer financial institutions and public comments about the bank's CRA performance
  • Tests of the bank's lending, investment, and banking services to the communities the bank conducts business in -- with attention given to the bank's business competition and opportunity, product offerings, and business strategy

Lending Test

The OCC measures the bank's performance in meeting the credit needs of areas in which the bank's main offices, branches, and deposit-taking ATMs are located, with consideration of the following:
  • Home mortgage, small business, small farm, and community development loans
  • Lending activity, geographic distribution of loans, borrower characteristics, community development lending, and the bank's use of innovative or flexible lending practices to meet the needs of low- and moderate- income communities

Investment Test

The OCC evaluates the bank's community development investments -- including both tax credit and equity investments, as well as charitable donations -- based on the following:
  • Dollar amount, innovation, complexity and responsiveness to credit and community development needs
  • Whether the bank meets community needs unmet by private investors
  • Geographic distribution of the bank's investments

Service Test

The OCC evaluates retail banking and community development services, including:
  • The number of branches and distribution in low- and moderate-income areas
  • Alternatives for delivering retail banking services in underserved communities
  • Qualifying community service hours provided by the bank's employees on behalf of the bank