PUBLIC DISCLOSURE MAY 22, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE ...
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PUBLIC DISCLOSURE MAY 22, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE ... Profile:
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......authors of this page or responsible for its content. PUBLIC DISCLOSURE MAY 22, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION CITIZENS-UNION SAVINGS BANK PUBLIC DISCLOSURE MAY 22, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION CITIZENS-UNION SAVINGS BANK 4 SOUTH MAIN STREET FALL RIVER, MA 02721 DIVISION OF BANKS ONE SOUTH STATION BOSTON, MA 02110 NOTE: This evaluation is not, nor should it be construed as, an assessment of the
financial condition of this institution. The rating assigned to this institution
does not represent an analysis, conclusion or opinion of the Division of
Banks concerning the safety and soundness of this financial institution. 1 GENERAL INFORMATION
The Community Reinvestment Act (CRA) requires the Massachusetts Division of Banks (Division) to use its authority when examining financial institutions subject to its
supervision, to evaluate the institution's record of meeting the needs of its entire
assessment area, including low and moderate-income neighborhoods, consistent with safe
and sound operation of the institution. Upon conclusion of such examination, the Division
must prepare a written evaluation of the institution's record of meeting the credit needs of
its assessment area.
This document is an evaluation of the CRA performance of CITIZENS-UNION SAVINGS BANK (or the Bank) prepared by the Division, the institution's supervisory agency.
INSTITUTION'S CRA RATING: This institution is rated "High Satisfactory"
Based on the Intermediate Small Bank CRA evaluation procedures specified for institutions
with assets under $1 billion and over $250 million, Citizens-Union Savings Banks overall
CRA performance is considered High Satisfactory.
Lending Test
The Banks loan-to-deposit ratio stood at 83.7 percent as of March 31, 2006, and averaged
70.9 percent over the last 8 quarters. These figures exemplify good performance levels
based on the Banks size, customer credit needs, and the market in which it operates.
Mortgage loan data for calendar years 2004 and 2005 indicates that, at 87.3 percent, a
majority of residential mortgages were originated inside the Banks assessment area
and, at 81 percent, a substantial majority of small business loans were originated inside
the assessment area.
The Banks level of lending among borrowers of different income levels and business
revenues reflects reasonable penetration.
The Banks relatively recent extension into the New Bedford area expands the
assessment areas low-income census tracts more than two-fold.
Community Development Test
The Banks community development performance demonstrates good responsiveness to
the community development needs of its assessment area through its community
development loans, qualified investments, and community development services.
2 GENERAL INFORMATION (CONTINUED)
Citizens-Union Savings Bank became an Intermediate Small Bank for CRA purposes as
of year end 2004. This is the first evaluation utilizing the Intermediate Small Bank
examination procedures for this Bank. The loan data considered for this evaluation
consisted of residential mortgages as reported under the Home Mortgage Disclosure
Act (HMDA) for 2004 and 2005. Small Business data was also reviewed for 2004 and
2005 since commercial lending represents 19.5 percent of the Banks loan portfolio as
of March 31, 2006, and because the Bank collects the data for small business lending.
Data for 2004 and 2005 will be presented in this evaluation. Aggregate loan data for
2004 is also included. Aggregate data for 2004 is the latest data available for
comparative analysis and is used to evaluate the Banks performance in contrast to all
other lenders that originated loans within the Banks assessment area. 3 PERFORMANCE CONTEXT
Description of Institution
Citizens-Union Savings Bank is a state chartered institution headquartered in Fall River,
Massachusetts. The Bank is a subsidiary of Narragansett Financial Corporation, a one
bank holding company. In addition to the Banks main office, eight other full-service branch
offices are located throughout the assessment area. Each branchs normal business hours
are 9:00 am to 4:00 pm. The following table details the location, extended business hours,
and census tract designation of each full service branch office.
Branch Location Extended Hours** Census Tract Main Office Fall River Fri to 5 pm Low income Stafford Road* Fall River Thur/Fri to 6 pm Sat 9 am to 12 noon Moderate Income Robeson Street* Fall River Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income Troy Street* Fall River Thur/Fri to 6 pm Sat 9 am to 12 noon Low Income Somerset Office* Somerset Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income Swansea Office* Swansea Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income Seekonk Office* Seekonk Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income New Bedford Office* New Bedford Thur/Fri to 6 pm Sat 9 am to 12 noon Low Income Tiverton Office* Tiverton, Rhode Island Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income * Drive-up Service from 7:30 am weekdays and 8:00 am Saturday morning
The Bank provides Automated Teller Machine (ATM) service at all locations. In addition,
the Bank offers web banking for customer convenience. The Banks ATM service is
connected to the NYCE and Cirrus networks. In addition, the Bank is a participant in the
SUM alliance of surcharge-free ATMs. This service allows the Bank's customers
surcharge-free use of ATMs operated by other SUM member institutions. The Bank
also offers banking by phone and online banking.
As of March 31, 2006, the Banks assets totaled $546 million of which $371.8 million or
68.1 percent represented total loans. The Bank is primarily a real estate lender with 71.1
percent of its loan portfolio consisting of residential real estate loans. Loans on nonfarm
nonresidential properties comprise 12.3 percent of the portfolio. The remaining portfolio
consists of construction and land development loans and commercial and industrial loans
that represent 7.9 percent and 7.2 percent of the total loan portfolio, respectively.
Additional information regarding the composition of the Banks loan portfolio is summarized
below. 4 PERFORMANCE CONTEXT (CONTINUED) Loan Distribution as of March 31, 2006 Loan Type Dollar Amount $(000) Percent (%) Secured by: Construction and Land Development 29,359 7.9 1-4 Family Residential Properties 252,244 67.9 Multi Family (5 or more) Residential Properties 12,067 3.2 Nonfarm Nonresidential Properties 45,673 12.3 Commercial and Industrial Loans 26,802 7.2 Consumer Loans 5,062 1.4 Other 583 0.2 Total 371,790 100.0 Source: Report of Condition The Bank continues to offer numerous loan products that include residential mortgages,
home equity loans, home improvement loans, construction loans, commercial real
estate loans, commercial loans, Small Business Loans, and consumer loans.
The Bank has a twelve member CRA Committee that meets quarterly. The committee is
comprised of the following: the CRA Officer who is Senior Vice President and Senior Loan
Officer; a Senior Vice President and Commercial Loan Officer; two Vice Presidents of
Retail Lending Vice President and Treasurer, Vice President and Commercial Loan Officer,
Vice President and Marketing Director, Vice President Branch Administration, Branch
Manager and Assistant Treasurer, Compliance Officer, and two mortgage originators. The
committees responsibilities include reviewing the geographic distribution of loans and
deposits and reviewing and comparing market data.
The Bank was last examined for compliance with the CRA on July 19, 2004 by the Federal
Deposit Insurance Corporation (FDIC) under the Large Bank CRA examination
procedures. A CRA rating of Satisfactory was assigned. The Bank was last examined by
the Division under the Large Bank CRA examination procedures on October 2, 2001 where
the Bank obtained a "High Satisfactory" rating. For the current examination, the Bank has
chosen to be examined under the new Intermediate Small Institution examination
procedures.
There appears to be no significant financial or legal impediments which would limit the
Banks ability to help meet the various credit needs of the defined assessment area.
Description of Assessment Area
CRA requires financial institutions to define an assessment area within which its lending
efforts are focused. The Division evaluates the institutions CRA performance based upon
the defined assessment area.
Citizens-Union Savings Bank has defined its assessment area to include the Cities of Fall
River and New Bedford and the Towns of Acushnet, Dartmouth, Dighton, Fairhaven,
Freetown, Rehoboth, Seekonk, Somerset, Swansea and Westport in Massachusetts and
the Towns of Little Compton and Tiverton in Rhode Island. All cities and towns are 5 PERFORMANCE CONTEXT (CONTINUED)
located in the Providence-New Bedford-Fall River, RI-MA Metropolitan Statistical Area
(MSA). The Banks assessment area is comprised of contiguous communities based on
branch office location. In November 2004, the Bank opened a full service branch office in
New Bedford. At that time the assessment area was redefined to include New Bedford and
the contiguous municipalities of Acushnet, Dartmouth, and Fairhaven. With the addition of
these municipalities the assessment area gained an additional 45 census tracts, more than
double the number of tracts of the previous assessment area. Currently, the assessment
area contains 87 census tracts. The following tables provide a comparison of the significant
changes in the demographic characteristics of the redefined assessment area.
Demographic Information for 2003 Assessment Area 2003 Low Moderate Middle Upper Demographic Characteristics # % of # % of # % of # % of # Geographies (Census Tracts/BNAs) 42 4.76 35.71 45.24 14.29 Population by Geography 188,881 2.12 32.62 48.33 16.93 Owner-Occupied Housing by Geography 44,052 0.83 16.53 59.95 22.69 Business by Geography 9,292 7.21 24.55 50.42 17.82 Farms by Geography 340 1.47 8.53 49.12 40.88 Family Distribution by Income Level 51,629 23.02 17.87 22.86 36.25 Distribution of Low and Moderate Income 21,110 3.02 46.98 40.00 10.00 HUD Adjusted Median Family Income for 2003
Households Below Poverty Level $58,400 11.74% Median Housing Value
Unemployment Rate (2000 US Census) $146,093 2.67% Source: 2000 Census Demographic Information for 2005 Assessment Area 2005 Low Moderate Middle Upper Demographic Characteristics # % of # % of # % of # % of # Geographies (Census Tracts/BNAs) 87 13.79 34.48 39.08 12.64 Population by Geography 348,107 8.42 30.95 45.42 15.21 Owner-Occupied Housing by Geography 79,903 3.45 19.54 57.52 19.49 Business by Geography 17,251 13.61 23.47 47.55 15.38 Farms by Geography 532 5.08 8.08 51.69 35.15 Family Distribution by Income Level 93,289 25.55 18.27 22.33 33.85 Distribution of Low and Moderate Income 40,887 12.81 41.94 37.21 8.04 HUD Adjusted Median Family Income for 2005
Households Below Poverty Level $64,750 13.56% Median Housing Value
Unemployment Rate (2000 US Census) $147,213 6.54% Source: 2000 Census The 2004 and 2005 median family incomes for the Providence-New Bedford-Fall River
MSA, as adjusted by the Department of Housing and Urban Development (HUD), are
$61,300 and $64,750, respectively. The median housing values, as indicated in the above
tables, are based on 2000 census. Similar to much of Massachusetts, the areas housing
prices have increased significantly. Recent statistics published by the Warren Group
indicates that the median home sales prices for calendar year 2005 ranged from a low of
$232,000 in New Bedford to a high of $393,750 in Little Compton, Rhode Island. The
average median sales price of a home in the Banks assessment area is $302,334.
Median housing values have increased an average of 20 percent since 2003. The rising
home prices continue to present an impediment for some individuals seeking
homeownership.
The assessment areas population is a mix of income levels, however, the largest
percentage of total households are low and moderate-income (43.2 percent).
6 PERFORMANCE CONTEXT (CONTINUED)
The defined assessment area appears to meet all technical requirements of the regulation
and does not arbitrarily exclude low and moderate-income areas. With the exception of the
two Rhode Island communities the assessment area does not extend much beyond the
boundaries of the Commonwealth of Massachusetts.
Census demographic information for 2000 obtained from CRA WIZ indicates that the
Banks assessment area contains a total population of 348,107 individuals. There are
147,592 housing units within the assessment area of which 54.2 percent are owner-
occupied, 38.8 percent are rental occupied and 7.0 percent are vacant housing units.
Consistent with the areas relatively modest characteristics, households living below
poverty level represent 13.6 percent of total households compared to 10 percent for the
Commonwealth.
The following table provides demographic and economic information pertaining to the
Banks assessment area.
Selected Housing Characteristics by Income Category of the Geography Percentage Geographic
Income
Category Census Tracts House- holds Housing Units Owner- Occupied Rental Units Vacant Units Median Home Value Low 13.8 28.6 9.6 3.5 17.0 15.3 104,151 Moderate 34.5 14.6 33.5 19.5 52.3 37.4 117,371 Middle 39.1 17.2 43.5 57.5 25.9 33.0 143,672 Upper 12.6 39.6 13.4 19.5 4.8 14.3 177,762 Total of Median 100.0 100.0 100.0 100.0 100.0 100.0 147,213 Source: 2000 U.S. Census
There are 17,251 businesses operating within the banks defined assessment area with
8,203, or 47.55 percent located in middle-income geographies. 7 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA
Intermediate Small Bank CRA evaluation procedures were used to assess the Banks CRA
performance. These procedures utilize two performance tests: the Lending Test and the
Community Development Test. The Lending Test considers the institutions performance
pursuant to the following criteria: loan-to-deposit (LTD) ratio, lending in the assessment
area, lending to borrowers of different incomes, geographic distribution of loans, and the
record of taking action in response to CRA complaints.
The Community Development Test considers the number and amount of any community
development loans, qualified investments, and community development services.
LENDING TEST
Citizens-Union Savings Bank has established itself as an active real estate and commercial
lender, specifically small business lending. The evaluation included a review of the Banks
home mortgage lending record. Data was derived from the Loan Application Registers
(LARs) maintained by the Bank pursuant to HMDA. The LARs contained data relative to
home purchase and home improvement loan activity, including refinanced transactions on
one-to-four family and multifamily properties. Small business loans for the purposes of this
evaluation include commercial real estate loans and commercial and industrial loans with
original balances of $1 million or less. Information concerning small business lending was
derived from the small business register maintained by the Bank. All loan activity
considered in the Lending Test was for calendar years 2004 and 2005. Aggregate data for
2004, the most recent year for which comparative aggregate data is available, was also
evaluated. Aggregate lending data provides information on the lending patterns of other
HMDA reporting entities that originated residential or small business loans in the Banks
assessment area.
1. LOAN TO DEPOSIT RATIO
This performance criterion determines what percentage of the Banks deposit base is
reinvested in the form of loans. The appropriateness of the Banks LTD was evaluated.
The Banks average LTD ratio of 70.9 is reasonable given the Banks size and assessment
area credit needs.
The LTD analysis utilized the last eight quarters of the Federal Financial Institutions
Examination Council (FFIEC) Call Report data for this institution. The Bank's net
loans to total deposits as reported to the FFIEC were reviewed for the quarters ending
June 30, 2004 through March 31, 2006. The following chart indicates that for the period
reviewed, the Banks net LTD ratio increased from a low of 58.4 percent at second
quarter 2004 to a high of 83.7 percent as of first quarter 2006. 8 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED) 58.4% 65.9% 68.2% 68.3% 71.1% 73.2% 78.3% 83.7% 0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0% 50.0% 55.0% 60.0% 65.0% 70.0% 75.0% 80.0% 85.0% 90.0% 95.0% 100.0% Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 CITIZENS-UNION SAVINGS BANK QUARTERLY NET LOAN-TO-DEPOSIT RATIOS June 2004-March 2006
Based on call report data for the period, the increase in loans to deposits was attributed to
loan growth that outpaced deposit growth. This was indicated largely by significant
increases in loans on 1 to 4 family residential properties and nonfarm nonresidential
properties.
2. Lending in the Assessment Area This performance criterion measures the percentage of the Banks lending that benefits
assessment area residents and businesses and evaluates the adequacy of such lending.
The following table shows the distribution of the Banks lending inside and outside of its
assessment area.
Distribution of HMDA Loans Inside and Outside the Assessment Area Number of Loans Dollars Inside Outside Inside Outside Total
Year # % # % Total $ % $ % 2004 336 86.6 52 13.4 388 50,272 80.6 12,135 19.4 62,407 2005 397 87.8 55 12.2 452 71,828 84.7 12,959 15.3 84,787
Total 733 87.3 107 12.7 840 122,100 83.0 25,094 17.0 147,194 Source: HMDA LAR 9 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
Data regarding the Banks residential lending activity for 2004 and 2005 was used to
provide a contrast of the Banks level of lending by number and dollar amount inside the
assessment area in comparison to lending outside the assessment area. These loans
consisted of first and second mortgages and home improvement loans on one to four
family properties. Refinanced mortgages represented 37.3 percent of total loans on
residential properties, while home improvement loans and purchases represented 29.8
percent and 20.2 percent of total loans, respectively.
As indicated in the preceding table, the Bank originated 840 HMDA-reportable loans
during this period. Of this number, 733 loans or 87.3 percent were originated within the
Banks assessment area. The dollar volume of loans inside the assessment area was
slightly lower at 83.0 percent, or $122.1 million, of the total dollar volume of $147.2
million. The data presented above for HMDA-reportable loans indicate that the Bank
extends a substantial majority of its loans, by number and dollar amount, within the
assessment area.
Also, a substantial majority of the Banks small business lending is within the assessment
area. As noted in the following table, the Bank originated business loans totaling $39
million. The Bank originated 81 percent of the total number and 79.2 percent of the total
dollar volume of small business loans within the assessment area for the period reviewed.
Small business loans have remained relatively consistent by volume and dollar amount.
Distribution of Small Business Loans Inside and Outside the Assessment Area Number of Loans Dollars Inside Outside Inside Outside
Year # % # % Total $ % $ % Total 2004 62 81.6 14 18.4 76 13,250 83.8 2,566 16.2 15,816 2005 66 80.5 16 19.5 82 17,709 76.2 5,541 23.8 23,250 Total 128 81.0 30 19.0 158 30,959 79.2 8,107 20.8 39,066 Source: HMDA LAR
Overall, the Banks performance has demonstrated a good level of lending within the
assessment area. As mentioned in the description of the assessment area, the area is
diverse in that it contains significant residential, commercial, and industrial
development. The Banks performance shows that small business lending by number
and dollar volume benefits the assessment areas businesses.
3. Lending to Borrowers of Different Income Levels and Businesses of Different
Sizes
The distribution of loans by borrower income was reviewed to determine the extent to
which the Bank is addressing the credit needs of the areas residents and small
businesses. Based on the review of the HMDA LARs and the Small Business Loan
Registers, the Bank has achieved good penetration among individuals of different
income levels, including low and moderate-income, and businesses of different revenue
sizes. 10 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED) Residential Lending
The distribution of residential loans to borrowers of different incomes reflects good
penetration among all income levels.
The analysis of borrower income level was identified as the ratio of borrower income to
the median family income 1 for the assessment area towns located within the MSA. The median family income is based upon estimated 2004 and 2005 HUD information for the
Providence-New Bedford-Fall River,RI-MA MSA for 2004 and 2005. The 2004 and
2005 median family incomes for the MSA were $61,300 and $64,750, respectively.
The following table indicates loans originated and categorized by the applicants reported
income in relation to the median family income for the MSA in which the property is
located. Loans to borrowers of low- and moderate-income represented 7.5 percent and
20.3 percent of total loans, respectively. Loans extended to borrowers with incomes within
the middle and upper-income level for the MSA median family income was 29.5 percent
and 39.6 percent, respectively. The following table provides a detailed breakdown of
residential loans originated by number categorized by the applicants income level.
Distribution of HMDA Loans by Borrower Income Aggregate Lending Data
(% of #) 2004 2004 2005 Total Median
Family
Income
Level
% Families¹ # % # % # % # % Low 25.6 940 5.3 27 8.0 28 7.0 55 7.5 Moderate 18.3 3,701 20.7 64 19.0 85 21.4 149 20.3 Middle 22.3 5,886 32.9 104 31.0 112 28.2 216 29.5 Upper 33.8 6,396 35.8 133 39.6 157 39.6 290 39.6 NA 0.0 956 5.3 8 2.4 15 3.8 23 3.1 Total 100.00 17,879 100.0 336 100.0 397 100.0 733 100.0 Source: ¹2000 U.S. Census, CRA WIZ HMDA Aggregate Data
The Banks loan data within the various income levels for calendar year 2004 was also
compared to 2004 loan data of all other lenders, the latest data available for aggregate
loan information. The results of the analysis indicated that the Bank's lending among
low and moderate-income borrowers was at a level that was commensurate to other
HMDA reporters. Based upon the analysis of borrower income, the distribution of
residential loans indicates good penetration among borrowers of different income levels. 1 As defined by the U.S. Department of Housing and Urban Development (HUD) Low-income is defined as income level or area that earns less than 50 percent of the MSAs median family income. Moderate-income is
defined as an income level that is 50 percent to less than 80 percent of the MSAs median family income.
Middle-income is defined as an income level that is 80 percent to less than 120 percent of the MSA median
family income, while upper-income is defined as an income level that is equal to or greater than 120 percent
of the MSAs median family income.
11 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED) Small Business Loans
The Bank has an adequate distribution of small business loans by business revenue and
loan size. As noted in Table 1a, for 2004 the Bank originated 62.1 percent of its small
business loans in amounts of $100,000 or less. While that is significantly less than the
95.2 percent for the aggregate, the aggregate data includes business credit cards that are
not necessarily to smaller businesses. However, the Banks lending to businesses with
revenues of $1 million or less at 46.8 percent, as indicated in Table 1a, is significantly more
than the 33.4 percent for the aggregate.
Distribution of Small Business Loans by Size 1a Percent of Loans by Loan Size Business
Revenue Aggregate 2004 Bank 2004 $100,000 and Less Between $100,000 and $250,000 $250,000 to $1 million # % # % # % # % # % $1 million 5,337 33.4 29 46.8 18 62.1 4 28.6 7 36.8 > $1 million 10,596 66.5 33 53.2 11 37.9 10 71.4 12 63.2 Total 15,933 100.0 62 100.0 29 46.8 14 22.6 19 30.6 Source:2004 CRA Small Business data
The distribution of small business loans for 2005 is consistent with the 2004 analysis. Distribution of Small Business Loans by Size 1a Percent of Loans by Loan Size Bank 2005 $100,000 and Less Between $100,000 and $250,000 $250,000 to $1 million
Business
Revenue # % # % # % # % $1 million 32 48.5 17 68.0 8 53.3 7 26.9 > $1 million 34 51.5 8 32.0 7 46.7 19 73.1 Total 66 100.0 25 37.9 15 22.7 26 39.4 Source:2005 CRA Small Business data 4. Geographic Distribution
The geographic distribution of loans was reviewed to assess how well the Bank is
addressing the credit needs throughout the assessment area. Based on the review of
the HMDA LARs and the CRA small business loan data, the geographic distribution of
loans reflects a reasonable dispersion throughout the assessment area. As mentioned
in the performance context, the Banks assessment area contains 12 low-income
census tracts, 30 moderate-income census tracts, 34 middle-income census tracts and
11 upper-income census tracts.
Residential Lending
The analysis of the Banks loan originations indicates that 9 loans or 1.2 percent were
located in low-income census tracts, 153 loans or 20.9 percent were located in
moderate-income census tracts, 440 loans or 60.0 percent were located in 12 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
middle-income census tracts and 131 loans or 17.9 percent were located in
upper-income census tracts.
In addition, the following table compares Bank data with 2004 aggregate data. As
indicated, the Banks penetration within the moderate-income census tracts, similar to the
aggregate, was slightly higher than the owner-occupancy rate within the moderate-income
tracts. Conversely, the Banks rate of lending in low-income tracts is considerably less than
the aggregate and the owner-occupancy rate within the low-income tracts. As mentioned
earlier, the number of low-income tracts more than doubled with the expansion into the
New Bedford area. Since more than 80 percent of the Banks low-income tracts are
located in New Bedford and the Banks physical presence in the New Bedford area is
relatively recent, lending in the low-income tracts has been nominal, as expected. As
indicated in the following table, lending in the remaining tract categories is similar to the
aggregate and is consistent with the rate of owner-occupancy within the assessment area.
Refer to the following table for more detailed information. Distribution of HMDA Loans by Income Category of the Census Tract Aggregate Lending Data (% of #) 2004 2005 Total Census
Tract
Income Level % Total Owner-occupied Housing Units¹ 2004 # % # % # % Low 3.5 5.4 4 1.2 5 1.2 9 1.2 Moderate 19.5 24.1 73 21.7 80 20.2 153 20.9 Middle 57.5 52.9 199 59.2 241 60.7 440 60.0 Upper 19.5 17.6 60 17.9 71 17.9 131 17.9 Total 100.0 100.0 336 100.0 397 100.0 733 100.0 Source: ¹2000 U.S. Census, HMDA LAR HMDA Aggregate Data.
Small Business Loans
Depicted in the following table is the geographic distribution of small business loans within
the assessment area. Included in the table are the percentages of lending within the
census tracts of different incomes as submitted by all reporters of small business data.
The Banks small business lending within the assessment areas moderate-income tracts is
especially notable and exceeds both the aggregates lending in this area and the
percentage of businesses in moderate-income geographies. The Banks lending within the
low-income census tracts is slightly below the aggregate but showed stronger activity in
2005.
Distribution of Small Business Loans by Income Category of the Census Tract Aggregate Lending Data (% of #) 2004 2005 Total Census
Tract
Income Level % Total Number of Small Businesses * 2004 # % # % # % Low 13.6 6.5 3 4.8 11 16.7 14 11.0 Moderate 23.4 12.7 25 40.3 21 31.8 46 35.9 Middle 47.6 43.1 27 43.6 31 46.9 58 45.3 Upper 15.4 37.7 7 11.3 3 4.6 10 7.8 Total 100.0 100.0 62 100.0 66 100.0 128 100.0 Source: CRA small business data. *2000 US Census. 13 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
The strong performance in lending within moderate-income tracts is at a level that exceeds
the percentage of small businesses within those tracts. Lending in low-income tracts
increased significantly in 2005 and surpassed the percentage of small businesses in low-
income tracts. The geographic distribution reflects good dispersion throughout the
assessment area.
5. REVIEW OF COMPLAINTS/ FAIR LENDING POLICIES AND PRACTICES
Based upon the review of the Banks public comment file and its performance relative to
fair lending policies and practices, no violations of the anti-discrimination laws and
regulations were identified.
The Banks Fair Lending Policy was reviewed to determine how this information relates to
the guidelines established by Regulatory Bulletin 2.3-101, the Division's Community
Reinvestment and Fair Lending Policy. The Banks Fair Lending Policy addresses specific
areas relating to internal and external employee training. The Bank has written fair lending
policy with guidelines established for staff training.
A thorough review of the public comment file revealed that the Bank received no
complaints pertaining to the institutions CRA performance since the previous examination.
Sample reviews of the Banks approved and non-originated residential loan application
files were conducted verify compliance. No practices that would result in disparate
treatment were noted.
MINORITY APPLICATION FLOW
A review of residential loan applications was conducted in order to determine the number
of HMDA-reportable credit applications the Bank received from minority applicants.
Between 2004 and 2005, the Bank received a total of 875 residential loan applications from
within its assessment area. During this period, 16 applications, or 1.8 percent, were
received from minorities and 3 or 0.3 percent from applicants of Hispanic or Latino
ethnicity. Of the total minority and Hispanic applications received, all were approved.
The Banks minority application flow for this period was compared with the racial and
ethnic make-up of the assessment area and the 2004 aggregate data for all other HMDA
reporters within the assessment area. The comparison of these data assists in deriving
reasonable expectations for the rate of applications the Bank received from minority
residential loan applicants.
According to 2000 Census Data, the Banks assessment area contained a total
population of 348,107 individuals, 13.12 percent of which is representative of various
racial and ethnic minorities. The comparison between the 2004 aggregate data and the
Bank data indicates that total applications received from racial and ethnic minority
applicants, at 7.6 percent compared to 1.75 percent for the Bank. 14 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
Refer to the following table for further details:
Minority Application Flow* Race 2004 Aggregate Data Bank 2004 Bank 2005 Bank Total # % # % # % # % American Indian/Alaska Native 147 0.4 0 0.00 0 0.00 0 0.00 Asian 222 0.6 1 0.25 4 0.85 5 0.57 Black or African American 1,071 2.9 3 0.75 1 0.21 4 0.46 Hawaiian/Pacific Islander 61 0.2 1 0.25 1 0.21 2 0.23 2 or More Minority Races 10 0.0 0 0.00 0 0.0 0 0.00 Joint Race (White/Minority) 245 0.7 1 0.25 4 0.85 5 0.57 Total Minority 1,756 4.8 6 1.50 10 2.12 16 1.83 White 26,119 71.4 341 84.60 396 83.90 737 84.23 Race Not Available 8,711 23.8 56 13.90 66 13.98 122 13.94 Total 36,586 100.0 403 100.0 472 100.0 875 100.0 Ethnicity Hispanic or Latino 1,039 2.8 1 0.25 2 0.42 3 0.34 Joint Hispanic/Not Hispanic 204 0.5 2 0.50 0 0.00 2 0.23 Not Hispanic or Latino 24,092 65.9 326 80.89 396 83.90 722 82.52 Ethnicity Not Available 11,251 30.8 74 18.36 74 15.68 148 16.91 *Source: PCI Services, Inc., CRA Wiz Software/HMDA LAR Data
15 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
COMMUNITY DEVELOPMENT TEST
Citizens-Union Savings Banks community development performance demonstrates good
responsiveness to the community development needs of its assessment area. The Bank
has met these community development needs through the provision of community
development loans, qualified grants, and community development services.
Community Development Loans:
For the purpose of this evaluation, a community development loan is defined as a loan that:
(1) has community development as its primary purpose, (2) has not already been reported
by the Bank for consideration under small business or home mortgage lending (unless it is
a multifamily dwelling loan), and (3) benefits the Banks assessment area or a broader
statewide area that includes the Banks assessment area.
Citizens-Union Savings Banks assessment area is economically diverse and with urban
and suburban characteristics with opportunities for community development lending. For
the period reviewed, the Bank originated 16 community development loans totaling
$5,077,863 in low- and moderate-income census tracts within the assessment area. Of the
total loans, 7 loans totaling $2.8 million were for the purchase or refinancing of multi-family
housing that provided lower than market rents in low and moderate-income areas in Fall
River.
Qualified community development lending within the assessment area are as follows:
In January 2004, the Bank provided a $500,000 line of credit renewal for working capital to a non-profit organization in Fall River that provides community services
including vocational, rehabilitation, residential, intervention, and advocacy services
to developmentally disabled low and moderate-income individuals. In June 2004, and July 2004 the Bank provided this same organization with two loans for $51,500 and $43,363, respectively, for the purchase of vans. In October 2004, the Bank provided a $100,000 renewal working capital line of credit to a non profit organization in Fall River that provides community services
targeted to low and moderate individuals for vocational, residential services and a
rehabilitation facility for drug and alcohol dependency. In February 2005, the Bank provided a $20,000 renewal working capital line of credit to a non profit organization located in a moderate-income area of Fall River
that provides education, transitional housing and shelter for homeless families. In January 2005, the Bank provided a $500,000 renewal line of credit to a non profit organization located in a moderate-income area of Fall River that provides
community services to low and moderate-income individuals with drug and alcohol
dependency. In May 2005, the Bank provided a $250,000 renewal line of credit to a non profit organization in a low-income census tract in Fall River that provides community
services to low and moderate-income individuals with housing, drug and alcohol
dependency issues. 16 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
In February 2006, the Bank provided a $750,000 renewal line of credit to a non- profit organization located in a moderate-income area of Fall River that provides
community services to low and moderate-income individuals with drug and alcohol
dependency. Qualified Investments
A qualified investment for the purposes of this CRA evaluation is a lawful investment,
deposit, membership share, or grant that has community development as its primary
purpose.
In 2004 the Bank made a $600,000 capital investment in a limited partnership for a 78 unit
senior housing complex with 30 units designated for low and moderate-income senior
citizens.
Southeastern Economic Development Corporation Ventures, LP- In 2004, the Bank made a limited partnership investment of $119,050 to this Small Business Investment
Company (SBIC) licensed partnership is chartered to provide subordinate debt financing to
new or emerging Southeastern Massachusetts businesses that otherwise would not qualify
for venture capital financing.
Access Capital Strategies Community Investment Fund- The Bank has an investment of $800,000 in this fund which purchases mortgage backed securities backed by affordable
mortgage loans in designated regions, including the Banks assessment area.
Citizens-Union Savings Banks qualified investments also consist of grants to organizations
that provide education and training, affordable housing, youth programs, and health and
human services primarily to lower-income residents. For calendar years 2004 and 2005 the
Bank has made donations totaling $104,486 that qualify as community development.
Organizations that have received benefit from the Banks efforts include the following: Boys
and Girls Clubs of Fall River and New Bedford, Consumer Credit Counseling Services,
Bristol Community College Fund, and the United Way of Greater Fall River.
Community Development Services
A Community Development Service has community development as its primary purpose
and is generally related to the provision of financial services or technical services or
assistance.
Employees of the Bank are involved in local community development services in various
capacities. 17 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
A Bank Senior Vice President is a current Corporator and past board member of Child and
Family Service, a non-profit agency that provides counseling services for families, children,
and adults in Southeastern Massachusetts.
The Banks President is a director of the Fall River Redevelopment Authority, a city agency
charged with management of the citys urban renewal projects.
The Banks President is co-chairman of the City of Fall River Mayors Task Force on
Homelessness.
A Bank Vice President serves as treasurer and board member of the Fall River YMCA.
A Bank Senior Vice President is co-chairman of the executive committee of the Fall River
Partnership, an apolitical body that acts as a resource to the Mayor and the city,
recommending courses of action relative to issues in education, transportation, business,
environment, and rehabilitation plans for the city.
A Bank Senior Vice President is a Board member of the Fall River Office of Economic
Development (Jobs for Fall River Inc.) a 501 C3 program that is administered by the Citys
Office of Economic Development and is responsible for lending programs designed to
assist Fall River businesses and foster overall economic development in the city.
A Bank Vice President is a member of the Board of Directors and Loan Committee of New
Bedford Economic Development Council, Inc. (NBEDC) a non-profit 501 C SBA certified
corporation set up in 1998 to improve the economy of New Bedford by assisting small
businesses to start-up, expand and create new jobs by providing various types of financial
and technical assistance.
A Bank Vice President and Board Director serve as Directors and finance committee
member of People Incorporated, a non profit agency providing housing and vocational
training for state assisted, mentally handicapped individuals.
A Bank Vice President is a member of the oversight committee of SEED Ventures, LLC, a
non-profit, SBA certified corporation set up in 2004 to improve the economy of
Southeastern Massachusetts by assisting small business to start-up, expand and create
new jobs by providing venture capital financial assistance.
A Bank Vice President is a member of the Micro Loan Committee of SEED Corp. a
non-profit SBA certified corporation set up in 1982 to improve the economy of
Southeastern Massachusetts by assisting small businesses to start-up, expand, and create
new jobs by providing various types of financial and technical assistance.
A Bank officer is a board member of the Boys and Girls Club of Fall River, an organization
that provides educational and recreational activities for low and moderate-income youth. 18 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
A Bank Vice President is a member of the board of Community Housing Resource Board,
a HUD financed organization that provides educational services to deal with affordable
housing issues and promote Fair Housing in Fall River.
A Bank Vice President is Financial Incentives Committee member of Downtown New
Bedford Inc., a non profit 501 C3 economic development organization for a specific region
of Downtown New Bedford.
A Bank Vice President is Chairman of the Board and President of Downtown New Bedford,
Inc., a non profit community organization committed to undertaking the activities designed
to preserve New Bedfords traditional downtown area as a healthy economically vital center
of commerce and activity.
Bank employees conduct weekly and bi-weekly banking sessions of the State Treasurers
Savings Makes Cents Program at 8 area elementary schools. This program provides
students with a first experience in operating a bank account and teaching the benefits of
savings for the future. PERFORMANCE EVALUATION DISCLOSURE GUIDE
Massachusetts General Laws Chapter 167, Section 14, as amended, and the
Uniform Interagency Community Reinvestment Act (CRA) Guidelines for Disclosure
of Written Evaluations require all financial institutions to take the following actions
within 30 business days of receipt of the CRA evaluation of their institution:
1) Make its most current CRA performance evaluation available to the public;
2) At a minimum, place the evaluation in the institution's CRA public file located
at the head office and at a designated office in each assessment area;
3) Add the following language to the institution's required CRA public notice that
is posted in each depository facility:
"You may obtain the public section of our most recent CRA Performance
Evaluation, which was prepared by the Massachusetts Division of Banks, at 4
South Main Street, Fall River, MA 02721"
[Please Note: If the institution has more than one assessment area, each
office (other than off-premises electronic deposit facilities) in that area shall
also include the address of the designated office for that assessment area.]
4) Provide a copy of its current evaluation to the public, upon request. In connection with this, the institution is authorized to charge a fee which does
not exceed the cost of reproduction and mailing (if applicable).
The format and content of the institution's evaluation, as prepared by its supervisory
agency, may not be altered or abridged in any manner. The institution is
encouraged to include its response to the evaluation in its CRA public file.
......authors of this page or responsible for its content. PUBLIC DISCLOSURE MAY 22, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION CITIZENS-UNION SAVINGS BANK PUBLIC DISCLOSURE MAY 22, 2006 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION CITIZENS-UNION SAVINGS BANK 4 SOUTH MAIN STREET FALL RIVER, MA 02721 DIVISION OF BANKS ONE SOUTH STATION BOSTON, MA 02110 NOTE: This evaluation is not, nor should it be construed as, an assessment of the
financial condition of this institution. The rating assigned to this institution
does not represent an analysis, conclusion or opinion of the Division of
Banks concerning the safety and soundness of this financial institution. 1 GENERAL INFORMATION
The Community Reinvestment Act (CRA) requires the Massachusetts Division of Banks (Division) to use its authority when examining financial institutions subject to its
supervision, to evaluate the institution's record of meeting the needs of its entire
assessment area, including low and moderate-income neighborhoods, consistent with safe
and sound operation of the institution. Upon conclusion of such examination, the Division
must prepare a written evaluation of the institution's record of meeting the credit needs of
its assessment area.
This document is an evaluation of the CRA performance of CITIZENS-UNION SAVINGS BANK (or the Bank) prepared by the Division, the institution's supervisory agency.
INSTITUTION'S CRA RATING: This institution is rated "High Satisfactory"
Based on the Intermediate Small Bank CRA evaluation procedures specified for institutions
with assets under $1 billion and over $250 million, Citizens-Union Savings Banks overall
CRA performance is considered High Satisfactory.
Lending Test
The Banks loan-to-deposit ratio stood at 83.7 percent as of March 31, 2006, and averaged
70.9 percent over the last 8 quarters. These figures exemplify good performance levels
based on the Banks size, customer credit needs, and the market in which it operates.
Mortgage loan data for calendar years 2004 and 2005 indicates that, at 87.3 percent, a
majority of residential mortgages were originated inside the Banks assessment area
and, at 81 percent, a substantial majority of small business loans were originated inside
the assessment area.
The Banks level of lending among borrowers of different income levels and business
revenues reflects reasonable penetration.
The Banks relatively recent extension into the New Bedford area expands the
assessment areas low-income census tracts more than two-fold.
Community Development Test
The Banks community development performance demonstrates good responsiveness to
the community development needs of its assessment area through its community
development loans, qualified investments, and community development services.
2 GENERAL INFORMATION (CONTINUED)
Citizens-Union Savings Bank became an Intermediate Small Bank for CRA purposes as
of year end 2004. This is the first evaluation utilizing the Intermediate Small Bank
examination procedures for this Bank. The loan data considered for this evaluation
consisted of residential mortgages as reported under the Home Mortgage Disclosure
Act (HMDA) for 2004 and 2005. Small Business data was also reviewed for 2004 and
2005 since commercial lending represents 19.5 percent of the Banks loan portfolio as
of March 31, 2006, and because the Bank collects the data for small business lending.
Data for 2004 and 2005 will be presented in this evaluation. Aggregate loan data for
2004 is also included. Aggregate data for 2004 is the latest data available for
comparative analysis and is used to evaluate the Banks performance in contrast to all
other lenders that originated loans within the Banks assessment area. 3 PERFORMANCE CONTEXT
Description of Institution
Citizens-Union Savings Bank is a state chartered institution headquartered in Fall River,
Massachusetts. The Bank is a subsidiary of Narragansett Financial Corporation, a one
bank holding company. In addition to the Banks main office, eight other full-service branch
offices are located throughout the assessment area. Each branchs normal business hours
are 9:00 am to 4:00 pm. The following table details the location, extended business hours,
and census tract designation of each full service branch office.
Branch Location Extended Hours** Census Tract Main Office Fall River Fri to 5 pm Low income Stafford Road* Fall River Thur/Fri to 6 pm Sat 9 am to 12 noon Moderate Income Robeson Street* Fall River Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income Troy Street* Fall River Thur/Fri to 6 pm Sat 9 am to 12 noon Low Income Somerset Office* Somerset Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income Swansea Office* Swansea Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income Seekonk Office* Seekonk Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income New Bedford Office* New Bedford Thur/Fri to 6 pm Sat 9 am to 12 noon Low Income Tiverton Office* Tiverton, Rhode Island Thur/Fri to 6 pm Sat 9 am to 12 noon Middle Income * Drive-up Service from 7:30 am weekdays and 8:00 am Saturday morning
The Bank provides Automated Teller Machine (ATM) service at all locations. In addition,
the Bank offers web banking for customer convenience. The Banks ATM service is
connected to the NYCE and Cirrus networks. In addition, the Bank is a participant in the
SUM alliance of surcharge-free ATMs. This service allows the Bank's customers
surcharge-free use of ATMs operated by other SUM member institutions. The Bank
also offers banking by phone and online banking.
As of March 31, 2006, the Banks assets totaled $546 million of which $371.8 million or
68.1 percent represented total loans. The Bank is primarily a real estate lender with 71.1
percent of its loan portfolio consisting of residential real estate loans. Loans on nonfarm
nonresidential properties comprise 12.3 percent of the portfolio. The remaining portfolio
consists of construction and land development loans and commercial and industrial loans
that represent 7.9 percent and 7.2 percent of the total loan portfolio, respectively.
Additional information regarding the composition of the Banks loan portfolio is summarized
below. 4 PERFORMANCE CONTEXT (CONTINUED) Loan Distribution as of March 31, 2006 Loan Type Dollar Amount $(000) Percent (%) Secured by: Construction and Land Development 29,359 7.9 1-4 Family Residential Properties 252,244 67.9 Multi Family (5 or more) Residential Properties 12,067 3.2 Nonfarm Nonresidential Properties 45,673 12.3 Commercial and Industrial Loans 26,802 7.2 Consumer Loans 5,062 1.4 Other 583 0.2 Total 371,790 100.0 Source: Report of Condition The Bank continues to offer numerous loan products that include residential mortgages,
home equity loans, home improvement loans, construction loans, commercial real
estate loans, commercial loans, Small Business Loans, and consumer loans.
The Bank has a twelve member CRA Committee that meets quarterly. The committee is
comprised of the following: the CRA Officer who is Senior Vice President and Senior Loan
Officer; a Senior Vice President and Commercial Loan Officer; two Vice Presidents of
Retail Lending Vice President and Treasurer, Vice President and Commercial Loan Officer,
Vice President and Marketing Director, Vice President Branch Administration, Branch
Manager and Assistant Treasurer, Compliance Officer, and two mortgage originators. The
committees responsibilities include reviewing the geographic distribution of loans and
deposits and reviewing and comparing market data.
The Bank was last examined for compliance with the CRA on July 19, 2004 by the Federal
Deposit Insurance Corporation (FDIC) under the Large Bank CRA examination
procedures. A CRA rating of Satisfactory was assigned. The Bank was last examined by
the Division under the Large Bank CRA examination procedures on October 2, 2001 where
the Bank obtained a "High Satisfactory" rating. For the current examination, the Bank has
chosen to be examined under the new Intermediate Small Institution examination
procedures.
There appears to be no significant financial or legal impediments which would limit the
Banks ability to help meet the various credit needs of the defined assessment area.
Description of Assessment Area
CRA requires financial institutions to define an assessment area within which its lending
efforts are focused. The Division evaluates the institutions CRA performance based upon
the defined assessment area.
Citizens-Union Savings Bank has defined its assessment area to include the Cities of Fall
River and New Bedford and the Towns of Acushnet, Dartmouth, Dighton, Fairhaven,
Freetown, Rehoboth, Seekonk, Somerset, Swansea and Westport in Massachusetts and
the Towns of Little Compton and Tiverton in Rhode Island. All cities and towns are 5 PERFORMANCE CONTEXT (CONTINUED)
located in the Providence-New Bedford-Fall River, RI-MA Metropolitan Statistical Area
(MSA). The Banks assessment area is comprised of contiguous communities based on
branch office location. In November 2004, the Bank opened a full service branch office in
New Bedford. At that time the assessment area was redefined to include New Bedford and
the contiguous municipalities of Acushnet, Dartmouth, and Fairhaven. With the addition of
these municipalities the assessment area gained an additional 45 census tracts, more than
double the number of tracts of the previous assessment area. Currently, the assessment
area contains 87 census tracts. The following tables provide a comparison of the significant
changes in the demographic characteristics of the redefined assessment area.
Demographic Information for 2003 Assessment Area 2003 Low Moderate Middle Upper Demographic Characteristics # % of # % of # % of # % of # Geographies (Census Tracts/BNAs) 42 4.76 35.71 45.24 14.29 Population by Geography 188,881 2.12 32.62 48.33 16.93 Owner-Occupied Housing by Geography 44,052 0.83 16.53 59.95 22.69 Business by Geography 9,292 7.21 24.55 50.42 17.82 Farms by Geography 340 1.47 8.53 49.12 40.88 Family Distribution by Income Level 51,629 23.02 17.87 22.86 36.25 Distribution of Low and Moderate Income 21,110 3.02 46.98 40.00 10.00 HUD Adjusted Median Family Income for 2003
Households Below Poverty Level $58,400 11.74% Median Housing Value
Unemployment Rate (2000 US Census) $146,093 2.67% Source: 2000 Census Demographic Information for 2005 Assessment Area 2005 Low Moderate Middle Upper Demographic Characteristics # % of # % of # % of # % of # Geographies (Census Tracts/BNAs) 87 13.79 34.48 39.08 12.64 Population by Geography 348,107 8.42 30.95 45.42 15.21 Owner-Occupied Housing by Geography 79,903 3.45 19.54 57.52 19.49 Business by Geography 17,251 13.61 23.47 47.55 15.38 Farms by Geography 532 5.08 8.08 51.69 35.15 Family Distribution by Income Level 93,289 25.55 18.27 22.33 33.85 Distribution of Low and Moderate Income 40,887 12.81 41.94 37.21 8.04 HUD Adjusted Median Family Income for 2005
Households Below Poverty Level $64,750 13.56% Median Housing Value
Unemployment Rate (2000 US Census) $147,213 6.54% Source: 2000 Census The 2004 and 2005 median family incomes for the Providence-New Bedford-Fall River
MSA, as adjusted by the Department of Housing and Urban Development (HUD), are
$61,300 and $64,750, respectively. The median housing values, as indicated in the above
tables, are based on 2000 census. Similar to much of Massachusetts, the areas housing
prices have increased significantly. Recent statistics published by the Warren Group
indicates that the median home sales prices for calendar year 2005 ranged from a low of
$232,000 in New Bedford to a high of $393,750 in Little Compton, Rhode Island. The
average median sales price of a home in the Banks assessment area is $302,334.
Median housing values have increased an average of 20 percent since 2003. The rising
home prices continue to present an impediment for some individuals seeking
homeownership.
The assessment areas population is a mix of income levels, however, the largest
percentage of total households are low and moderate-income (43.2 percent).
6 PERFORMANCE CONTEXT (CONTINUED)
The defined assessment area appears to meet all technical requirements of the regulation
and does not arbitrarily exclude low and moderate-income areas. With the exception of the
two Rhode Island communities the assessment area does not extend much beyond the
boundaries of the Commonwealth of Massachusetts.
Census demographic information for 2000 obtained from CRA WIZ indicates that the
Banks assessment area contains a total population of 348,107 individuals. There are
147,592 housing units within the assessment area of which 54.2 percent are owner-
occupied, 38.8 percent are rental occupied and 7.0 percent are vacant housing units.
Consistent with the areas relatively modest characteristics, households living below
poverty level represent 13.6 percent of total households compared to 10 percent for the
Commonwealth.
The following table provides demographic and economic information pertaining to the
Banks assessment area.
Selected Housing Characteristics by Income Category of the Geography Percentage Geographic
Income
Category Census Tracts House- holds Housing Units Owner- Occupied Rental Units Vacant Units Median Home Value Low 13.8 28.6 9.6 3.5 17.0 15.3 104,151 Moderate 34.5 14.6 33.5 19.5 52.3 37.4 117,371 Middle 39.1 17.2 43.5 57.5 25.9 33.0 143,672 Upper 12.6 39.6 13.4 19.5 4.8 14.3 177,762 Total of Median 100.0 100.0 100.0 100.0 100.0 100.0 147,213 Source: 2000 U.S. Census
There are 17,251 businesses operating within the banks defined assessment area with
8,203, or 47.55 percent located in middle-income geographies. 7 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA
Intermediate Small Bank CRA evaluation procedures were used to assess the Banks CRA
performance. These procedures utilize two performance tests: the Lending Test and the
Community Development Test. The Lending Test considers the institutions performance
pursuant to the following criteria: loan-to-deposit (LTD) ratio, lending in the assessment
area, lending to borrowers of different incomes, geographic distribution of loans, and the
record of taking action in response to CRA complaints.
The Community Development Test considers the number and amount of any community
development loans, qualified investments, and community development services.
LENDING TEST
Citizens-Union Savings Bank has established itself as an active real estate and commercial
lender, specifically small business lending. The evaluation included a review of the Banks
home mortgage lending record. Data was derived from the Loan Application Registers
(LARs) maintained by the Bank pursuant to HMDA. The LARs contained data relative to
home purchase and home improvement loan activity, including refinanced transactions on
one-to-four family and multifamily properties. Small business loans for the purposes of this
evaluation include commercial real estate loans and commercial and industrial loans with
original balances of $1 million or less. Information concerning small business lending was
derived from the small business register maintained by the Bank. All loan activity
considered in the Lending Test was for calendar years 2004 and 2005. Aggregate data for
2004, the most recent year for which comparative aggregate data is available, was also
evaluated. Aggregate lending data provides information on the lending patterns of other
HMDA reporting entities that originated residential or small business loans in the Banks
assessment area.
1. LOAN TO DEPOSIT RATIO
This performance criterion determines what percentage of the Banks deposit base is
reinvested in the form of loans. The appropriateness of the Banks LTD was evaluated.
The Banks average LTD ratio of 70.9 is reasonable given the Banks size and assessment
area credit needs.
The LTD analysis utilized the last eight quarters of the Federal Financial Institutions
Examination Council (FFIEC) Call Report data for this institution. The Bank's net
loans to total deposits as reported to the FFIEC were reviewed for the quarters ending
June 30, 2004 through March 31, 2006. The following chart indicates that for the period
reviewed, the Banks net LTD ratio increased from a low of 58.4 percent at second
quarter 2004 to a high of 83.7 percent as of first quarter 2006. 8 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED) 58.4% 65.9% 68.2% 68.3% 71.1% 73.2% 78.3% 83.7% 0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0% 50.0% 55.0% 60.0% 65.0% 70.0% 75.0% 80.0% 85.0% 90.0% 95.0% 100.0% Jun-04 Sep-04 Dec-04 Mar-05 Jun-05 Sep-05 Dec-05 Mar-06 CITIZENS-UNION SAVINGS BANK QUARTERLY NET LOAN-TO-DEPOSIT RATIOS June 2004-March 2006
Based on call report data for the period, the increase in loans to deposits was attributed to
loan growth that outpaced deposit growth. This was indicated largely by significant
increases in loans on 1 to 4 family residential properties and nonfarm nonresidential
properties.
2. Lending in the Assessment Area This performance criterion measures the percentage of the Banks lending that benefits
assessment area residents and businesses and evaluates the adequacy of such lending.
The following table shows the distribution of the Banks lending inside and outside of its
assessment area.
Distribution of HMDA Loans Inside and Outside the Assessment Area Number of Loans Dollars Inside Outside Inside Outside Total
Year # % # % Total $ % $ % 2004 336 86.6 52 13.4 388 50,272 80.6 12,135 19.4 62,407 2005 397 87.8 55 12.2 452 71,828 84.7 12,959 15.3 84,787
Total 733 87.3 107 12.7 840 122,100 83.0 25,094 17.0 147,194 Source: HMDA LAR 9 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
Data regarding the Banks residential lending activity for 2004 and 2005 was used to
provide a contrast of the Banks level of lending by number and dollar amount inside the
assessment area in comparison to lending outside the assessment area. These loans
consisted of first and second mortgages and home improvement loans on one to four
family properties. Refinanced mortgages represented 37.3 percent of total loans on
residential properties, while home improvement loans and purchases represented 29.8
percent and 20.2 percent of total loans, respectively.
As indicated in the preceding table, the Bank originated 840 HMDA-reportable loans
during this period. Of this number, 733 loans or 87.3 percent were originated within the
Banks assessment area. The dollar volume of loans inside the assessment area was
slightly lower at 83.0 percent, or $122.1 million, of the total dollar volume of $147.2
million. The data presented above for HMDA-reportable loans indicate that the Bank
extends a substantial majority of its loans, by number and dollar amount, within the
assessment area.
Also, a substantial majority of the Banks small business lending is within the assessment
area. As noted in the following table, the Bank originated business loans totaling $39
million. The Bank originated 81 percent of the total number and 79.2 percent of the total
dollar volume of small business loans within the assessment area for the period reviewed.
Small business loans have remained relatively consistent by volume and dollar amount.
Distribution of Small Business Loans Inside and Outside the Assessment Area Number of Loans Dollars Inside Outside Inside Outside
Year # % # % Total $ % $ % Total 2004 62 81.6 14 18.4 76 13,250 83.8 2,566 16.2 15,816 2005 66 80.5 16 19.5 82 17,709 76.2 5,541 23.8 23,250 Total 128 81.0 30 19.0 158 30,959 79.2 8,107 20.8 39,066 Source: HMDA LAR
Overall, the Banks performance has demonstrated a good level of lending within the
assessment area. As mentioned in the description of the assessment area, the area is
diverse in that it contains significant residential, commercial, and industrial
development. The Banks performance shows that small business lending by number
and dollar volume benefits the assessment areas businesses.
3. Lending to Borrowers of Different Income Levels and Businesses of Different
Sizes
The distribution of loans by borrower income was reviewed to determine the extent to
which the Bank is addressing the credit needs of the areas residents and small
businesses. Based on the review of the HMDA LARs and the Small Business Loan
Registers, the Bank has achieved good penetration among individuals of different
income levels, including low and moderate-income, and businesses of different revenue
sizes. 10 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED) Residential Lending
The distribution of residential loans to borrowers of different incomes reflects good
penetration among all income levels.
The analysis of borrower income level was identified as the ratio of borrower income to
the median family income 1 for the assessment area towns located within the MSA. The median family income is based upon estimated 2004 and 2005 HUD information for the
Providence-New Bedford-Fall River,RI-MA MSA for 2004 and 2005. The 2004 and
2005 median family incomes for the MSA were $61,300 and $64,750, respectively.
The following table indicates loans originated and categorized by the applicants reported
income in relation to the median family income for the MSA in which the property is
located. Loans to borrowers of low- and moderate-income represented 7.5 percent and
20.3 percent of total loans, respectively. Loans extended to borrowers with incomes within
the middle and upper-income level for the MSA median family income was 29.5 percent
and 39.6 percent, respectively. The following table provides a detailed breakdown of
residential loans originated by number categorized by the applicants income level.
Distribution of HMDA Loans by Borrower Income Aggregate Lending Data
(% of #) 2004 2004 2005 Total Median
Family
Income
Level
% Families¹ # % # % # % # % Low 25.6 940 5.3 27 8.0 28 7.0 55 7.5 Moderate 18.3 3,701 20.7 64 19.0 85 21.4 149 20.3 Middle 22.3 5,886 32.9 104 31.0 112 28.2 216 29.5 Upper 33.8 6,396 35.8 133 39.6 157 39.6 290 39.6 NA 0.0 956 5.3 8 2.4 15 3.8 23 3.1 Total 100.00 17,879 100.0 336 100.0 397 100.0 733 100.0 Source: ¹2000 U.S. Census, CRA WIZ HMDA Aggregate Data
The Banks loan data within the various income levels for calendar year 2004 was also
compared to 2004 loan data of all other lenders, the latest data available for aggregate
loan information. The results of the analysis indicated that the Bank's lending among
low and moderate-income borrowers was at a level that was commensurate to other
HMDA reporters. Based upon the analysis of borrower income, the distribution of
residential loans indicates good penetration among borrowers of different income levels. 1 As defined by the U.S. Department of Housing and Urban Development (HUD) Low-income is defined as income level or area that earns less than 50 percent of the MSAs median family income. Moderate-income is
defined as an income level that is 50 percent to less than 80 percent of the MSAs median family income.
Middle-income is defined as an income level that is 80 percent to less than 120 percent of the MSA median
family income, while upper-income is defined as an income level that is equal to or greater than 120 percent
of the MSAs median family income.
11 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED) Small Business Loans
The Bank has an adequate distribution of small business loans by business revenue and
loan size. As noted in Table 1a, for 2004 the Bank originated 62.1 percent of its small
business loans in amounts of $100,000 or less. While that is significantly less than the
95.2 percent for the aggregate, the aggregate data includes business credit cards that are
not necessarily to smaller businesses. However, the Banks lending to businesses with
revenues of $1 million or less at 46.8 percent, as indicated in Table 1a, is significantly more
than the 33.4 percent for the aggregate.
Distribution of Small Business Loans by Size 1a Percent of Loans by Loan Size Business
Revenue Aggregate 2004 Bank 2004 $100,000 and Less Between $100,000 and $250,000 $250,000 to $1 million # % # % # % # % # % $1 million 5,337 33.4 29 46.8 18 62.1 4 28.6 7 36.8 > $1 million 10,596 66.5 33 53.2 11 37.9 10 71.4 12 63.2 Total 15,933 100.0 62 100.0 29 46.8 14 22.6 19 30.6 Source:2004 CRA Small Business data
The distribution of small business loans for 2005 is consistent with the 2004 analysis. Distribution of Small Business Loans by Size 1a Percent of Loans by Loan Size Bank 2005 $100,000 and Less Between $100,000 and $250,000 $250,000 to $1 million
Business
Revenue # % # % # % # % $1 million 32 48.5 17 68.0 8 53.3 7 26.9 > $1 million 34 51.5 8 32.0 7 46.7 19 73.1 Total 66 100.0 25 37.9 15 22.7 26 39.4 Source:2005 CRA Small Business data 4. Geographic Distribution
The geographic distribution of loans was reviewed to assess how well the Bank is
addressing the credit needs throughout the assessment area. Based on the review of
the HMDA LARs and the CRA small business loan data, the geographic distribution of
loans reflects a reasonable dispersion throughout the assessment area. As mentioned
in the performance context, the Banks assessment area contains 12 low-income
census tracts, 30 moderate-income census tracts, 34 middle-income census tracts and
11 upper-income census tracts.
Residential Lending
The analysis of the Banks loan originations indicates that 9 loans or 1.2 percent were
located in low-income census tracts, 153 loans or 20.9 percent were located in
moderate-income census tracts, 440 loans or 60.0 percent were located in 12 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
middle-income census tracts and 131 loans or 17.9 percent were located in
upper-income census tracts.
In addition, the following table compares Bank data with 2004 aggregate data. As
indicated, the Banks penetration within the moderate-income census tracts, similar to the
aggregate, was slightly higher than the owner-occupancy rate within the moderate-income
tracts. Conversely, the Banks rate of lending in low-income tracts is considerably less than
the aggregate and the owner-occupancy rate within the low-income tracts. As mentioned
earlier, the number of low-income tracts more than doubled with the expansion into the
New Bedford area. Since more than 80 percent of the Banks low-income tracts are
located in New Bedford and the Banks physical presence in the New Bedford area is
relatively recent, lending in the low-income tracts has been nominal, as expected. As
indicated in the following table, lending in the remaining tract categories is similar to the
aggregate and is consistent with the rate of owner-occupancy within the assessment area.
Refer to the following table for more detailed information. Distribution of HMDA Loans by Income Category of the Census Tract Aggregate Lending Data (% of #) 2004 2005 Total Census
Tract
Income Level % Total Owner-occupied Housing Units¹ 2004 # % # % # % Low 3.5 5.4 4 1.2 5 1.2 9 1.2 Moderate 19.5 24.1 73 21.7 80 20.2 153 20.9 Middle 57.5 52.9 199 59.2 241 60.7 440 60.0 Upper 19.5 17.6 60 17.9 71 17.9 131 17.9 Total 100.0 100.0 336 100.0 397 100.0 733 100.0 Source: ¹2000 U.S. Census, HMDA LAR HMDA Aggregate Data.
Small Business Loans
Depicted in the following table is the geographic distribution of small business loans within
the assessment area. Included in the table are the percentages of lending within the
census tracts of different incomes as submitted by all reporters of small business data.
The Banks small business lending within the assessment areas moderate-income tracts is
especially notable and exceeds both the aggregates lending in this area and the
percentage of businesses in moderate-income geographies. The Banks lending within the
low-income census tracts is slightly below the aggregate but showed stronger activity in
2005.
Distribution of Small Business Loans by Income Category of the Census Tract Aggregate Lending Data (% of #) 2004 2005 Total Census
Tract
Income Level % Total Number of Small Businesses * 2004 # % # % # % Low 13.6 6.5 3 4.8 11 16.7 14 11.0 Moderate 23.4 12.7 25 40.3 21 31.8 46 35.9 Middle 47.6 43.1 27 43.6 31 46.9 58 45.3 Upper 15.4 37.7 7 11.3 3 4.6 10 7.8 Total 100.0 100.0 62 100.0 66 100.0 128 100.0 Source: CRA small business data. *2000 US Census. 13 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
The strong performance in lending within moderate-income tracts is at a level that exceeds
the percentage of small businesses within those tracts. Lending in low-income tracts
increased significantly in 2005 and surpassed the percentage of small businesses in low-
income tracts. The geographic distribution reflects good dispersion throughout the
assessment area.
5. REVIEW OF COMPLAINTS/ FAIR LENDING POLICIES AND PRACTICES
Based upon the review of the Banks public comment file and its performance relative to
fair lending policies and practices, no violations of the anti-discrimination laws and
regulations were identified.
The Banks Fair Lending Policy was reviewed to determine how this information relates to
the guidelines established by Regulatory Bulletin 2.3-101, the Division's Community
Reinvestment and Fair Lending Policy. The Banks Fair Lending Policy addresses specific
areas relating to internal and external employee training. The Bank has written fair lending
policy with guidelines established for staff training.
A thorough review of the public comment file revealed that the Bank received no
complaints pertaining to the institutions CRA performance since the previous examination.
Sample reviews of the Banks approved and non-originated residential loan application
files were conducted verify compliance. No practices that would result in disparate
treatment were noted.
MINORITY APPLICATION FLOW
A review of residential loan applications was conducted in order to determine the number
of HMDA-reportable credit applications the Bank received from minority applicants.
Between 2004 and 2005, the Bank received a total of 875 residential loan applications from
within its assessment area. During this period, 16 applications, or 1.8 percent, were
received from minorities and 3 or 0.3 percent from applicants of Hispanic or Latino
ethnicity. Of the total minority and Hispanic applications received, all were approved.
The Banks minority application flow for this period was compared with the racial and
ethnic make-up of the assessment area and the 2004 aggregate data for all other HMDA
reporters within the assessment area. The comparison of these data assists in deriving
reasonable expectations for the rate of applications the Bank received from minority
residential loan applicants.
According to 2000 Census Data, the Banks assessment area contained a total
population of 348,107 individuals, 13.12 percent of which is representative of various
racial and ethnic minorities. The comparison between the 2004 aggregate data and the
Bank data indicates that total applications received from racial and ethnic minority
applicants, at 7.6 percent compared to 1.75 percent for the Bank. 14 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
Refer to the following table for further details:
Minority Application Flow* Race 2004 Aggregate Data Bank 2004 Bank 2005 Bank Total # % # % # % # % American Indian/Alaska Native 147 0.4 0 0.00 0 0.00 0 0.00 Asian 222 0.6 1 0.25 4 0.85 5 0.57 Black or African American 1,071 2.9 3 0.75 1 0.21 4 0.46 Hawaiian/Pacific Islander 61 0.2 1 0.25 1 0.21 2 0.23 2 or More Minority Races 10 0.0 0 0.00 0 0.0 0 0.00 Joint Race (White/Minority) 245 0.7 1 0.25 4 0.85 5 0.57 Total Minority 1,756 4.8 6 1.50 10 2.12 16 1.83 White 26,119 71.4 341 84.60 396 83.90 737 84.23 Race Not Available 8,711 23.8 56 13.90 66 13.98 122 13.94 Total 36,586 100.0 403 100.0 472 100.0 875 100.0 Ethnicity Hispanic or Latino 1,039 2.8 1 0.25 2 0.42 3 0.34 Joint Hispanic/Not Hispanic 204 0.5 2 0.50 0 0.00 2 0.23 Not Hispanic or Latino 24,092 65.9 326 80.89 396 83.90 722 82.52 Ethnicity Not Available 11,251 30.8 74 18.36 74 15.68 148 16.91 *Source: PCI Services, Inc., CRA Wiz Software/HMDA LAR Data
15 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
COMMUNITY DEVELOPMENT TEST
Citizens-Union Savings Banks community development performance demonstrates good
responsiveness to the community development needs of its assessment area. The Bank
has met these community development needs through the provision of community
development loans, qualified grants, and community development services.
Community Development Loans:
For the purpose of this evaluation, a community development loan is defined as a loan that:
(1) has community development as its primary purpose, (2) has not already been reported
by the Bank for consideration under small business or home mortgage lending (unless it is
a multifamily dwelling loan), and (3) benefits the Banks assessment area or a broader
statewide area that includes the Banks assessment area.
Citizens-Union Savings Banks assessment area is economically diverse and with urban
and suburban characteristics with opportunities for community development lending. For
the period reviewed, the Bank originated 16 community development loans totaling
$5,077,863 in low- and moderate-income census tracts within the assessment area. Of the
total loans, 7 loans totaling $2.8 million were for the purchase or refinancing of multi-family
housing that provided lower than market rents in low and moderate-income areas in Fall
River.
Qualified community development lending within the assessment area are as follows:
In January 2004, the Bank provided a $500,000 line of credit renewal for working capital to a non-profit organization in Fall River that provides community services
including vocational, rehabilitation, residential, intervention, and advocacy services
to developmentally disabled low and moderate-income individuals. In June 2004, and July 2004 the Bank provided this same organization with two loans for $51,500 and $43,363, respectively, for the purchase of vans. In October 2004, the Bank provided a $100,000 renewal working capital line of credit to a non profit organization in Fall River that provides community services
targeted to low and moderate individuals for vocational, residential services and a
rehabilitation facility for drug and alcohol dependency. In February 2005, the Bank provided a $20,000 renewal working capital line of credit to a non profit organization located in a moderate-income area of Fall River
that provides education, transitional housing and shelter for homeless families. In January 2005, the Bank provided a $500,000 renewal line of credit to a non profit organization located in a moderate-income area of Fall River that provides
community services to low and moderate-income individuals with drug and alcohol
dependency. In May 2005, the Bank provided a $250,000 renewal line of credit to a non profit organization in a low-income census tract in Fall River that provides community
services to low and moderate-income individuals with housing, drug and alcohol
dependency issues. 16 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
In February 2006, the Bank provided a $750,000 renewal line of credit to a non- profit organization located in a moderate-income area of Fall River that provides
community services to low and moderate-income individuals with drug and alcohol
dependency. Qualified Investments
A qualified investment for the purposes of this CRA evaluation is a lawful investment,
deposit, membership share, or grant that has community development as its primary
purpose.
In 2004 the Bank made a $600,000 capital investment in a limited partnership for a 78 unit
senior housing complex with 30 units designated for low and moderate-income senior
citizens.
Southeastern Economic Development Corporation Ventures, LP- In 2004, the Bank made a limited partnership investment of $119,050 to this Small Business Investment
Company (SBIC) licensed partnership is chartered to provide subordinate debt financing to
new or emerging Southeastern Massachusetts businesses that otherwise would not qualify
for venture capital financing.
Access Capital Strategies Community Investment Fund- The Bank has an investment of $800,000 in this fund which purchases mortgage backed securities backed by affordable
mortgage loans in designated regions, including the Banks assessment area.
Citizens-Union Savings Banks qualified investments also consist of grants to organizations
that provide education and training, affordable housing, youth programs, and health and
human services primarily to lower-income residents. For calendar years 2004 and 2005 the
Bank has made donations totaling $104,486 that qualify as community development.
Organizations that have received benefit from the Banks efforts include the following: Boys
and Girls Clubs of Fall River and New Bedford, Consumer Credit Counseling Services,
Bristol Community College Fund, and the United Way of Greater Fall River.
Community Development Services
A Community Development Service has community development as its primary purpose
and is generally related to the provision of financial services or technical services or
assistance.
Employees of the Bank are involved in local community development services in various
capacities. 17 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
A Bank Senior Vice President is a current Corporator and past board member of Child and
Family Service, a non-profit agency that provides counseling services for families, children,
and adults in Southeastern Massachusetts.
The Banks President is a director of the Fall River Redevelopment Authority, a city agency
charged with management of the citys urban renewal projects.
The Banks President is co-chairman of the City of Fall River Mayors Task Force on
Homelessness.
A Bank Vice President serves as treasurer and board member of the Fall River YMCA.
A Bank Senior Vice President is co-chairman of the executive committee of the Fall River
Partnership, an apolitical body that acts as a resource to the Mayor and the city,
recommending courses of action relative to issues in education, transportation, business,
environment, and rehabilitation plans for the city.
A Bank Senior Vice President is a Board member of the Fall River Office of Economic
Development (Jobs for Fall River Inc.) a 501 C3 program that is administered by the Citys
Office of Economic Development and is responsible for lending programs designed to
assist Fall River businesses and foster overall economic development in the city.
A Bank Vice President is a member of the Board of Directors and Loan Committee of New
Bedford Economic Development Council, Inc. (NBEDC) a non-profit 501 C SBA certified
corporation set up in 1998 to improve the economy of New Bedford by assisting small
businesses to start-up, expand and create new jobs by providing various types of financial
and technical assistance.
A Bank Vice President and Board Director serve as Directors and finance committee
member of People Incorporated, a non profit agency providing housing and vocational
training for state assisted, mentally handicapped individuals.
A Bank Vice President is a member of the oversight committee of SEED Ventures, LLC, a
non-profit, SBA certified corporation set up in 2004 to improve the economy of
Southeastern Massachusetts by assisting small business to start-up, expand and create
new jobs by providing venture capital financial assistance.
A Bank Vice President is a member of the Micro Loan Committee of SEED Corp. a
non-profit SBA certified corporation set up in 1982 to improve the economy of
Southeastern Massachusetts by assisting small businesses to start-up, expand, and create
new jobs by providing various types of financial and technical assistance.
A Bank officer is a board member of the Boys and Girls Club of Fall River, an organization
that provides educational and recreational activities for low and moderate-income youth. 18 CONCLUSIONS WITH RESPECT TO PERFORMANCE CRITERIA (CONTINUED)
A Bank Vice President is a member of the board of Community Housing Resource Board,
a HUD financed organization that provides educational services to deal with affordable
housing issues and promote Fair Housing in Fall River.
A Bank Vice President is Financial Incentives Committee member of Downtown New
Bedford Inc., a non profit 501 C3 economic development organization for a specific region
of Downtown New Bedford.
A Bank Vice President is Chairman of the Board and President of Downtown New Bedford,
Inc., a non profit community organization committed to undertaking the activities designed
to preserve New Bedfords traditional downtown area as a healthy economically vital center
of commerce and activity.
Bank employees conduct weekly and bi-weekly banking sessions of the State Treasurers
Savings Makes Cents Program at 8 area elementary schools. This program provides
students with a first experience in operating a bank account and teaching the benefits of
savings for the future. PERFORMANCE EVALUATION DISCLOSURE GUIDE
Massachusetts General Laws Chapter 167, Section 14, as amended, and the
Uniform Interagency Community Reinvestment Act (CRA) Guidelines for Disclosure
of Written Evaluations require all financial institutions to take the following actions
within 30 business days of receipt of the CRA evaluation of their institution:
1) Make its most current CRA performance evaluation available to the public;
2) At a minimum, place the evaluation in the institution's CRA public file located
at the head office and at a designated office in each assessment area;
3) Add the following language to the institution's required CRA public notice that
is posted in each depository facility:
"You may obtain the public section of our most recent CRA Performance
Evaluation, which was prepared by the Massachusetts Division of Banks, at 4
South Main Street, Fall River, MA 02721"
[Please Note: If the institution has more than one assessment area, each
office (other than off-premises electronic deposit facilities) in that area shall
also include the address of the designated office for that assessment area.]
4) Provide a copy of its current evaluation to the public, upon request. In connection with this, the institution is authorized to charge a fee which does
not exceed the cost of reproduction and mailing (if applicable).
The format and content of the institution's evaluation, as prepared by its supervisory
agency, may not be altered or abridged in any manner. The institution is
encouraged to include its response to the evaluation in its CRA public file.