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#1100934 - 12/22/08 05:17 PM "Limited-Purpose" Institution & Strategic Plan
Complywithregs Offline
Member
Complywithregs
Joined: Apr 2006
Posts: 76
Kansas City, MO
First, CRA is not my best area so I"m pretty green.

I've read this: OTS CEO Memo March 4, 2008: Strategic Plan and Wholesale/Limited Purpose Designations Under the CRA.

Now: I need to find out if we are eligible to change our designation to a "limited purpose" institution as we want to just have our CRA tested under the Community Development Test. (as we will no longer do Mortgage Lending). Does anyone know or have an example of how to submit a letter or form to the regulator?
We have only had one CRA exam and it was done under all 3 test. WE are almost a 3 year old "large" bank.

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#1101005 - 12/22/08 06:48 PM Re: "Limited-Purpose" Institution & Strategic Plan Complywithregs
bubs63 Offline
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bubs63
Joined: May 2003
Posts: 665
Highland Park IL
Has your bank been designated as a limited purpose bank? Or did you just decide not to do mortgage loans. Just because you do not do mortgage loans you still maybe doing HMDA reportable loans on your commercial side.
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#1101012 - 12/22/08 07:00 PM Re: "Limited-Purpose" Institution & Strategic Plan bubs63
Complywithregs Offline
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Complywithregs
Joined: Apr 2006
Posts: 76
Kansas City, MO
No we haven't applied to the OTS to be designated as a limited purpose bank yet. I was hoping there would be some kind of form to fill out for that. We are trying to figure how to go about doing a Strategic Plan for our next CRA. We don't do Commercial Loans. So you think we have to absolutely be non-HMDA reportable to be considered a limited-purpose institution? We do OD Lines of Credit.

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#1101130 - 12/22/08 09:03 PM Re: "Limited-Purpose" Institution & Strategic Plan Complywithregs
bubs63 Offline
Platinum Poster
bubs63
Joined: May 2003
Posts: 665
Highland Park IL
No, but a limited purpose bank would be like a credit card bank, with a single purpose. I have not investigated stratigic plans but I do know they would involve public input when you are creating one.

You should talk to the OTS and see if they can get you a copy of a stratigic plan for you to review. If you go out to the OTS website they may have a sample of a plan also
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Bubs-

"truth does not occur in the database" - Actual search result on a goverment website

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#1101193 - 12/22/08 10:13 PM Re: "Limited-Purpose" Institution & Strategic Plan bubs63
Complywithregs Offline
Member
Complywithregs
Joined: Apr 2006
Posts: 76
Kansas City, MO
I have found a few Stratetic Plans that the OTS had on their site. There were the CRA Evaluations. That doesn't help in getting set up it just shows me the outcome of these institution that were reviewed as Strategic Plans. It would be ideal if I could see what their Strategic Plans looked like. As far as the limited purpose; we were just trying to get around the Lending Test.

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#1101238 - 12/23/08 01:26 AM Re: "Limited-Purpose" Institution & Strategic Plan Complywithregs
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,155
Connecticut
We just completed a Strategic Plan for a client bank that reports to the FDIC. As part of our process we identified other banks who had submitted Strategic Plans and contacted them. They were all willing to share their plans with us (after all, the plans had to be available for public comment originally). It was helpful. But the key is establishing your performance context and then proposing reasonable goals.
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