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Comptroller of the Currency Administrator of National Banks Midwestern District 2345 Grand Avenue, Suite 700 Kansas City, Missou

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Comptroller of the Currency Administrator of National Banks Midwestern District 2345 Grand Avenue, Suite 700 Kansas City, Missou Comptroller of the Currency Administrator of National Banks Midwestern District 2345 Grand Avenue, Suite 700 Kansas City, Missouri 64108 GENERAL INFORMATION This document is an evaluation of the Community Reinvestment Act (CRA) performance of Norwest Bank Iowa, National Association, Des Moines, Iowa prepared by the Office of the Comptroller of the Currency (OCC), the institution's supervisory agency. The evaluation represents the OCC's current assessment and rating of the institution's CRA performance based on an examination conducted as of July 25, 1996. It does not reflect any CRA-related activities that may have been initiated or discontinued by the institution after the completion of the examination. The purpose of the Community Reinvestment Act of 1977 (12 U.S.C. 2901), as amended, is to encourage each financial institution to help meet the credit needs of the communities in which it operates. The Act requires that in connection with its examination of a financial institution, each federal financial supervisory agency shall (1) assess the institution's record of helping to meet the credit needs of its entire community, including LMI neighborhoods, consistent with safe and sound operations of the institution, and (2) take that record of performance into account when deciding whether to approve an application of the institution for a deposit facility. The Financial Institutions Reform, Recovery and Enforcement Act of 1989, Pub. L. No. 101- 73, amended the CRA to require the Agencies to make public certain portions of their CRA performance assessments of financial institutions. Basis for the Rating The assessment of the institution's record takes into account its financial capacity and size, legal impediments and local economic conditions and demographics, including the competitive environment in which it operates. Assessing the CRA performance is a process that does not rely on absolute standards. Institutions are not required to adopt specific activities, nor to offer specific types or amounts of credit. Each institution has considerable flexibility in determining how it can best help to meet the credit needs of its entire community. In that light, evaluations are based on a review of 12 assessment factors, which are grouped together under 5 performance categories, as detailed in the following section of this evaluation. 2 ASSIGNMENT OF RATING Identification of Ratings In connection with the assessment of each insured depository institution's CRA performance, a rating is assigned from the following groups: Outstanding record of meeting community credit needs. An institution in this group has an outstanding record of, and is a leader in, ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities. Satisfactory record of meeting community credit needs. An institution in this group has a satisfactory record of ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities. Needs to improve record of meeting community credit needs. An institution in this group needs to improve its overall record of ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities. Substantial noncompliance in meeting community credit needs. An institution in this group has a substantially deficient record of ascertaining and helping to meet the credit needs of its entire delineated community, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities. 3 Norwest Bank Iowa, National Association DISCUSSION OF INSTITUTION'S PERFORMANCE Institution's Rating: Based on the findings presented below, Norwest Bank Iowa, National Association (Norwest) has an: C Outstanding Record of Meeting Community Credit Needs. The purpose of CRA is to ensure that financial institutions help meet the credit needs of their local communities. We rated this institution’s CRA record as Outstanding because: C Norwest, in conjunction with its affiliate, Norwest Mortgage, Inc. (NMI), originates a significant volume of Home Mortgage Disclosure Act (HMDA) loans within their Iowa markets. Combined, they are the market leader in originating HMDA loans in Iowa; C Norwest and NMI are the market leaders in originating HMDA loans in low- and moderate-income (LMI) census tracts (CTs) and to LMI applicants; and C Norwest actively participates in community development activities, providing needed leadership, technical and financial support. Bank Profile Norwest is a wholly-owned subsidiary of Norwest Corporation, a multi-bank holding company headquartered in Minneapolis, Minnesota. The bank is a full-service financial institution with retail credit and services as its primary business focus. Norwest has 12 community delineations, five in Metropolitan Statistical Areas (MSA) and seven in non-MSA markets. The five MSA delineations include markets in Des Moines, the Quad Cities, Cedar Rapids, Cedar Valley, and Sioux City. Non-MSA markets include the communities of Ames, Atlantic, Denison, Fort Dodge, Marshalltown, Mason City and Ottumwa. Fifty-three percent of Norwest’s deposit base originates from the Des Moines, Quad Cities and Cedar Rapids markets. Norwest has approximately 10% of all Iowa banking deposits. As of March 31, 1996, Norwest had approximately $6.3 billion in total assets. The bank’s loan-to-deposit ratio was 97% with a loan mix of 20% real estate, including 11% 1-4 family residential; 21% commercial; 56% consumer; 2% agricultural and 1% other. Most of the bank’s consumer loans are credit card receivables as Norwest houses the credit card operations and receivables for all Norwest affiliates. 4 Norwest Bank Iowa, National Association NMI originates most of the residential real estate loans in the bank’s markets through 41 loan originators. Originators are located in each market, with Des Moines having a total of 15. NMI lending activity within the bank’s delineated community was considered in this Evaluation. Community Profiles Norwest has 12 delineated communities in Iowa. The delineated communities include all or portions of 25 counties in Iowa, one county in South Dakota, and one county in Nebraska. All of the markets have several common credit needs, identified by bank management and verified through examiner contact with community organizations. These credit needs include loans for small business as well as home purchase and home improvement projects. The economies of the markets are stable with unemployment in the five MSAs at 3%. Usually, competition within each market is significant. We used the following 1995 delineations in this Evaluation of the bank’s CRA performance. Des Moines The Des Moines delineated community consists of Polk, Warren and Dallas Counties located within the Des Moines, IA MSA #2120. Based on 1990 Census data, the population of this area was approximately 393,000. Minorities comprise 7% of the population, including approximately 4% African Americans. The Des Moines MSA contains 98 CTs, of which 19 are designated as LMI. The Department of Housing and Urban Development’s (HUD) 1995 MSA Median Family Income for the Des Moines MSA is $36,300. According to bank prepared reports, Norwest has about 23% of the banking deposits within the Des Moines market. Quad Cities The Quad Cities delineation includes Scott County located within the Quad Cities, IA MSA #1960. Based on 1990 Census data, the population of this area was 151,000. Minorities comprise 9% of the population, including 5% African Americans. The Quad Cities delineated community contains 39 CTs, of which 10 are LMI. HUD 1995 MSA Median Family Income for the Quad Cities MSA is $33,600. According to bank reports, Norwest has about 10% of the banking deposits within the Quad Cities market. Cedar Rapids 5 Norwest Bank Iowa, National Association The Cedar Rapids delineated community consists of portions of Linn and Benton Counties located within the Cedar Rapids, IA MSA #1360. Based on 1990 Census data, the population of this area was 169,000. Minorities comprise 4% of the population, including 2% African Americans. The Cedar Rapids delineated community contains 40 CTs, of which 8 are LMI. HUD 1995 MSA Median Family Income for the Cedar Valley MSA is $35,100. According to bank reports, Norwest has about 18% of the banking deposits within the Cedar Rapids market. Cedar Valley (Cedar Falls/Waterloo) The Cedar Valley delineated community consists of Black Hawk and portions of Bremer, Butler, and Grundy Counties located within the Waterloo/Cedar Falls, IA MSA #8920. Based on 1990 Census data, the population of this area was 124,000. Minorities comprise 9% of the population, including 7% African Americans. The Cedar Valley delineated community contains 36 CTs, of which 12 are LMI. HUD 1995 MSA Median Family Income for the Cedar Valley MSA is $32,400. According to bank reports, Norwest has about 15% of the banking deposits within the Cedar Valley markets. Sioux City The Sioux City delineated community consists of portions of Woodbury and Plymouth Counties in Iowa, portions of Dakota County in Nebraska, and portions of Union County in South Dakota. The Sioux City delineation is within the Sioux City, IA MSA #7720. Based on 1990 Census data, the population of this area was 115,000. Minorities comprise 8% of the population, including 2% African Americans. The Sioux City delineated community contains 30 CTs, of which 8 are LMI. HUD 1995 MSA Median Family Income for the Sioux City MSA is $29,300. According to bank reports, Norwest has about 22% of the banking deposits within the Sioux City market. NonMSA Markets Norwest’s Mason City, Fort Dodge, Ottumwa, Ames, Marshalltown, and Denison markets are not located in MSAs. These communities rely primarily on agriculture for support, but a variety of industries provide modest diversification from agriculture.
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