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A bank formally appealed the management rating of 2 assigned at the most recent safety and soundness examination. The appeal states that the management rating is based solely on the "needs to improve" CRA rating without sufficient consideration of overall board and management supervision.
The Report of Examination stated that ''board oversight and management supervision are satisfactory; . . . however, they did not provide adequate oversight in complying with the requirements of CRA resulting in a 'needs to improve' rating''. OCC Bulletin 97-1, Uniform Financial Institutions Rating System, states that the capability and performance of management and the board of directors is rated based upon evaluation factors which include the level and quality of oversight and support of all institution activities by the board and management.
Based on the noted deficiencies in the bank's overall management and administration of its CRA activities, the ombudsman concluded that the assigned 2 management rating was appropriate.