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CRA Evaluation Charter No. (703786)

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CRA Evaluation Charter No. (703786) PUBLIC DISCLOSURE March 23, 2020 COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION First Federal Savings and Loan Association of Bath Charter Number: 703786 125 Front Street Bath, ME 04530-2610 Office of the Comptroller of the Currency 99 Summer Street Suite 1400 Boston, MA 02110 NOTE: This document is an evaluation of this institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, and should not 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 federal financial supervisory agency concerning the safety and soundness of this financial institution. Charter Number: 703786 Table of Contents Overall Community Reinvestment Act (CRA) Rating…………………………………………... 1 Description of Institution………….……………………………………………………………... 3 Scope of the Evaluation…………………………………………………………………………. 4 Discriminatory or Other Illegal Credit Practices Review……………………….………………. 6 Lending Test ……………………………………………………………………………………. 7 State Rating…….………………………………………………………………………………...10 Appendix A: Scope of Examination………….…………………………………………………A1 Appendix B: Summary of State Ratings…………………………………...................................B1 Appendix C: Definitions and Common Abbreviations………………………………………….C1 Appendix D: Tables of Performance Data………………………………………………………D1 i Charter Number: 703786 Overall CRA Rating Institution’s CRA Rating: This institution is rated Outstanding. The Lending Test is rated: Outstanding. The major factors that support this rating include: • The Lending Test (LT) rating is based on the State of Maine (ME) rating which stems from the First Federal Savings and Loan Association of Bath’s (“Bath” or “the Bank”) record of performance in meeting the credit needs of its ME-based assessment area (AA) during the CRA evaluation period of January 1, 2017 through December 31, 2019. • The State of ME LT rating is based on a combination of the ratings of Bath’s two full-scope (FS) ME rating areas which comprise the entirety of the Bank’s delineated AA, specifically the FS Portland-South Portland, ME Metropolitan Statistical Area (MSA) (#38860) and the FS ME non-MSA (#99999) ratings areas. Performance within the FS Portland-South Portland, ME MSA rating area was more heavily weighted when drawing final conclusions as 56 percent of the deposit base and 60 percent of primary product lending during this evaluation was located within this FS rating area. • The Bank’s average loan-to-deposit (LTD) ratio for the 22 quarters since the previous performance evaluation LTD analysis is considered more than reasonable and compares favorably to local peer groups. • During this evaluation’s timeframe, a substantial majority of the Bank’s primary product lending activity occurred within its delineated ME AA. • Lending levels reflect excellent responsiveness to AA credit needs. • There were no CRA or Fair Lending (FL) related complaints received by the Bank or the Office of the Comptroller of the Currency (OCC) during the evaluation period. 1 Charter Number: 703786 Loan-to-Deposit Ratio Given Bath’s size, financial condition, and credit needs of the AA, the Bank’s LTD ratio is considered more than reasonable. The Bank’s net LTD ratio averaged approximately 103 percent over the 22 quarters, July 1, 2014 through December 31, 2019, since the previous CRA performance evaluation. During this period, the LTD ratio ranged from a quarterly low of 92.87 percent and a quarterly high of 110.21 percent. The Bank’s LTD ratio compares favorably to other peer institutions located within the delineated AA, where the peer group’s net LTD ratio averaged approximately 85 percent over the same time-period, from a quarterly low of 72.15 percent to a quarterly high of 98.31 percent. Lending in Assessment Area A substantial majority of the Bank's primary product lending activity occurred within its delineated AA. The Bank originated and/or purchased 86.2 percent of its total loans inside the AA during the full evaluation period of January 1, 2017, through December 31, 2019. Additionally, Bath originated/purchased 84.3 percent by dollar amount of its total loans inside the AA during the evaluation period. This lending analysis was performed at the Bank, rather than the AA, level and meets the standard for outstanding performance. Lending Inside and Outside of the Assessment Area Number of Loans Dollar Amount of Loans $(000s) Loan Category Inside Outside Total Inside Outside Total # % # % # $ % $ % $(000s) Home Mortgage 2017 107 87.7 15 12.3 122 16,352 89.8 1,867 10.2 18,219 2018 125 89.3 15 10.7 140 18,663 84.4 3,455 15.6 22,119 2019 119 82.1 26 17.9 145 17,120 79.5 4,421 20.5 21,541 Subtotal 351 86.2 56 13.8 407 52,135 84.3 9,743 15.7 61,879 Total 351 86.2 56 13.8 407 52,135 84.3 9,743 15.7 61,879 Source: Evaluation Period: 1/1/2017 - 12/31/2019 Bank Data. Due to rounding, totals may not equal 100.0 2 Charter Number: 703786 Description of Institution Founded in 1935, First Federal Savings and Loan Association of Bath is a federally chartered intrastate mutual institution headquartered in Bath, Maine with $134.9 million in reported total assets as of December 31, 2019. The Bank does not maintain any operating subsidiaries or affiliate relationships that were considered as part of this performance evaluation. The Bank’s main office is in Bath, ME and also operates four other full-service branches serving the Sagadahoc, Lincoln, and portions of Cumberland Counties. Specifically, these other branches are located in Bath, Damariscotta, Boothbay Harbor, and Wiscasset ME – the two offices located in Bath are based in moderate-income census tracts, while the three remaining branches are located in either middle- or upper-income geographies. Office hours, at a minimum, run from 9:00 am to 4:00 pm Monday through Friday, with branch locations offering extended hours. No branches were closed during this performance evaluation’s timeframe. The Bank continues to offer a traditional suite of lending and deposit-based products for both personal and commercial lines of business, and the Bank’s website, www.firstfederalbath.com, provides a full listing of products and services offered. The Bank also maintains a variety of delivery channels and alternate methods of access for their banking customers, including: telephone banking, mobile banking applications, and online banking. Full-service automated service teller machines (ATMs) are housed at all office locations. Bath’s primary business consists of one- to four-family residential mortgage loans and to a much lesser extent, the Bank also originates commercial real estate loans, multi-family mortgage loans, and commercial business loans. As of December 31, 2019, Bath reported total assets, total deposits, and tier 1 capital of $134.9 million, $110.3 million, and $23.4 million, respectively. The loan portfolio totaled approximately $117.3 million or approximately 87 percent of total assets. The table below provides a summary of the loan mix as of December 31, 2019: Loan Portfolio Summary by Loan Product December 31, 2019 Loan Category % of Gross Loans and Leases 1-4 Family Residential Mortgages – Closed End 86 Other Real Estate (Commercial) 6 Home Equity 3 Construction & Development 2 Consumer 1 Commercial & Industrial 1 Multifamily <1 Total 100 Source: Federal Deposit Insurance Corporation Call Report, December 31, 2019 The Bank has no financial or legal impediments in meeting the credit needs of the AA. The Bank was rated ‘Outstanding’ using Small Bank (SB) procedures during the previous CRA performance evaluation dated October 14, 2014. 3 Charter Number: 703786 Scope of the Evaluation Evaluation Period/Products Evaluated First Federal Savings and Loan Association of Bath was evaluated using SB CRA evaluation procedures, which entails evaluating the Bank’s record in meeting the credit needs of its delineated AA via its record of lending during the evaluation period. The evaluation period for the LT, apart from the loan-to-deposit analysis, is January 1, 2017 through December 31, 2019. Our LTD analysis timeframe consists of the 22 quarters occurring since the previous CRA performance evaluation LTD analysis, specifically July 1, 2014 through December 31, 2019. Our conclusions as to the Bank’s lending performance during the evaluation period are based on a single identified primary product type, specifically residential mortgage loans as reported via Bath’s HMDA Loan Application Register (LAR) as this product type accounted for the majority of lending activity occurring during our evaluation period. During the evaluation period, residential mortgage loans accounted for approximately 48 percent by number and 80 percent by dollar amount of all loan originations. The Bank’s performance during the evaluation period was compared to 2015 American Community Survey (ACS) US Census, 2019 Dun & Bradstreet (D&B), and 2018 Home Mortgage Disclosure Act (HMDA) Aggregate data. Aggregate HMDA data for 2019 was not readily available for use as of this performance evaluation. Selection of Areas for Full-Scope Review In each state where the Bank has an office, one or more AAs within that state were selected for a full- scope review. For purposes of this evaluation, bank delineated assessment areas located within the same MSA, multistate metropolitan statistical area (MMSA), or combined statistical area (CSA) are combined and evaluated as a single AA. Similarly, bank delineated non-MSA AAs within the same state are combined and evaluated as a single area. The CRA requires an institution to define its AA in which it will be evaluated. Bath has delineated a single AA, comprised of two separate FS rating areas, that meet the requirements of the regulation by consisting of wholly-contiguous political subdivisions, contains the entirety of the customer deposit base, and does not arbitrarily exclude any low- or moderate-income census tracts.
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