Community Reinvestment Act Performance Evaluation
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NEW YORK STATE BANKING DEPARTMENT CONSUMER SERVICES DIVISION One State Street New York, NY 10004 PUBLIC SUMMARY COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION Date of Evaluation: December 31, 2009 Institution: Apple Bank for Savings 122 East 42nd Street New York, New York 10168-0002 Note: This evaluation is not an assessment of the financial condition of this institution. The rating assigned does not represent an analysis, conclusion or opinion of the New York State Banking Department concerning the safety and soundness of this financial institution. TABLE OF CONTENTS Section General Information ......................................................................... 1 Overview of Institution’s Performance .............................................. 2 Performance Context ........................................................................ 3 Institution Profile Assessment Area Demographic & Economic Data Community Information Performance Tests and Assessment Factors .................................. 4 Lending Test Investment Test Service Test Additional Factors Glossary ........................................................................................... 5 GENERAL INFORMATION This document is an evaluation of the Community Reinvestment Act (“CRA”) performance of Apple Bank for Savings (“Apple Bank”) prepared by the New York State Banking Department. The evaluation represents the Banking Department’s current assessment and rating of the institution’s CRA performance based on an evaluation conducted as of 12/31/2009. Section 28-b of the New York State Banking Law, as amended, requires that when evaluating certain applications, the Superintendent of Banks shall assess a banking institution’s record of helping to meet the credit needs of its entire community, including low- and moderate-income (“LMI”) areas, consistent with safe and sound operations. Part 76 of the General Regulations of the Banking Board implements Section 28-b and further requires that the Banking Department assess the CRA performance records of regulated financial institutions. Part 76 establishes the framework and criteria by which the Department will evaluate the performance. Section 76.5 further provides that the Banking Department will prepare a written report summarizing the results of such assessment and will assign to each institution a numerical CRA rating based on a 1 to 4 scoring system. The numerical scores represent an assessment of CRA performance as follows: (1) outstanding record of meeting community credit needs; (2) satisfactory record of meeting community credit needs; (3) needs to improve record of meeting community credit needs; and (4) substantial noncompliance in meeting community credit needs. Section 76.5 further requires that the CRA rating and the written summary be made available to the public (“Evaluation”). Evaluations of small banking institutions are primarily based on a review of performance tests and standards described in Section 76.7 and detailed in Section 76.12. The tests and standards incorporate the 12 assessment factors contained in Section 28-b of the New York State Banking Law. For an explanation of technical terms used in this report, please consult the GLOSSARY at the back of this document. 1-1 OVERVIEW OF INSTITUTION’S PERFORMANCE Apple Bank’s performance was evaluated according to the large bank performance criteria pursuant to Part 76.12 of the General Regulations of the Banking Board. This assessment period included calendar years 2007, 2008 and 2009. Apple Bank is rated “1,” indicating an “Outstanding” record of helping to meet community credit needs. This rating is based on the following factors: Lending Test – “Outstanding” • Apple Bank’s lending activity reflected good responsiveness considering its size, business strategy and financial condition, as well as peer group activity and demographics. • Apple Bank originated a substantial majority of its loans within the assessment area. During the evaluation period, Apple Bank originated 96% by number, and 95.8% by dollar value of its combined HMDA-reportable and MECA lending loans within its assessment area. • The distribution of loans based on lending in census tracts of varying income levels demonstrated a reasonable penetration rate of lending. • Apple Bank’s loan distribution based on borrower characteristics reflects a more than reasonable penetration among individuals of different income levels. Compared to the aggregate, Apple Bank’s record of lending to LMI individuals was more than reasonable for the evaluation period. • During the evaluation period, Apple Bank originated $139 million in new community development loans, and still had $37.8 million outstanding from prior evaluation periods. This demonstrated an excellent level of community development lending over the course of the evaluation period. • Apple Bank uses innovative and/or flexible lending practices in serving the credit needs of its assessment area. Investment Test: “Outstanding” During the evaluation period, Apple Bank made $306 million in new community development investments, and still had $33 million outstanding from prior evaluation periods. In addition, Apple Bank made $263 thousand in community development grants. This demonstrated an excellent level of community development investments and grants over the course of the evaluation period. 2-1 Service Test: “High Satisfactory” Apple Bank had and continues to have excellent delivery systems, branch network, branch hours and services, and alternative delivery systems. Apple Bank provides an adequate level of community development services. During the evaluation period, Apple Bank sponsored various seminars and events. These were conducted in conjunction with various non-profit organizations. This evaluation was conducted based on a review of the 12 assessment factors set forth in Section 28-b of the New York State Banking Law and Part 76 of the General Regulations of the Banking Board. 2-2 PERFORMANCE CONTEXT Institution Profile: Chartered in 1863, Apple Bank for Savings (Apple Bank) is a savings bank, located in Manhasset, New York. The bank is a wholly-owned subsidiary of Apple Financial Holdings, Inc. As of June 30, 2009, Apple Bank had seven active subsidiaries. As per the December 31, 2009 Consolidated Report of Condition (the Call Report) filed with the Federal Deposit Insurance Corporation (“FDIC”), Apple Bank reported total assets of $7.3 billion, of which $2.4 billion were net loans and lease financing receivables. It also reported total deposits of $5.9 billion, resulting in a loan-to- deposit ratio of 41.21%. According to the latest available comparative deposit data as of June 30, 2009, Apple Bank obtained a market share of .89%, or $5.9 billion out of $655.8 billion inside its market, ranking it 15th among 148 deposit-taking institutions in the assessment area. The following is a summary of Apple bank’s loan portfolio, based on Schedule RC-C of the bank’s December 31, 2007, 2008 and 2009 Call Reports: TOTAL GROSS LOANS OUTSTANDING 2007 2008 2009 Loan Type $000's % $000's % $000's % 1-4 Family Residential Mortgage Loans 808,110 60.0 974,675 59.5 937,661 38.3 Commercial & Industrial Loans 0.0 12,689 0.8 428,667 17.5 Commercial Mortgage Loans 289,602 21.5 376,604 23.0 577,210 23.6 Multifamily Mortgages 221,248 16.4 240,725 14.7 364,691 14.9 Consumer Loans 22,876 1.7 22,586 1.4 20,296 0.8 Agricultural Loans 0.0 0.0 0.0 Construction Loans 1,972 0.1 7,368 0.4 116,349 4.7 Obligations of States & Municipalities 0.0 0.0 0.0 Other Loans 3,305 0.2 4,812 0.3 5,459 0.2 Lease financing 0.0 0.0 0.0 Total Gross Loans 1,347,113 1,639,459 2,450,333 As illustrated in the above chart, Apple Bank is primarily a real estate lender, with 76.8% of its loan portfolio in real estate lending and 4.7 % construction lending as of December 31, 2009. There are no known financial or legal impediments that adversely impacted Apple Bank’s ability to meet the credit needs of its community. Assessment Area: 3 - 1 Apple Bank’s assessment area is comprised of eight counties; the Bronx, Kings, New York, Queens, Richmond, Westchester, Nassau and Suffolk. There are 3,035 census tracts in the area, of which 334 are low-income, 718 are moderate-income, 1,077 are middle-income, 828 are upper-income and 78 are tracts with no income indicated. Assessment Area Census Tracts by Income Level LMI & Dis- tressed County N/A Low Mod Middle Upper Total LMI % % Bronx 14 132 98 65 46 355 64.8 64.8% Kings 15 119 297 235 117 783 53.1 53.1% New York 9 60 59 24 144 296 40.2 40.2% Queens 18 12 148 310 185 673 23.8 23.8% Richmond 2 3 11 29 65 110 12.7 12.7% Westchester 4 4 21 39 153 221 11.3 11.3% Nassau 8 2 20 178 69 277 7.9 7.9% Suffolk 8 2 64 197 49 320 20.6 20.6% Total 78 334 718 1,077 828 3,035 34.7 34.7% The assessment area appears reasonable based upon the location of Apple Bank’s offices and its lending patterns. There is no evidence that LMI areas have been arbitrarily excluded. Demographic & Economic Data The assessment area had a population of 11.7 million during the evaluation period. About 12.3% of the population were over the age of 65 and 21.9% were under the age of 16. Of the 2,819,370 families in the assessment area, 26% were low-income, 16.7% were moderate-income, 18.6% were middle-income and 38.74% were upper-income families. There were 4,277,301 households in the assessment area, of which 15.8% had income below the poverty level and 5.9% were on public assistance. The MSA median family income within the assessment area was $54.7 thousand. The U.S. Department of Housing and Urban Development (“HUD”) estimated median family income for the area was $72.1 thousand in 2009. Nassau and Suffolk Counties, which had MSA median family income of $76.2 thousand and HUD estimated median family income of $101.8 thousand inflated the total assessment area figures, which would have been $49.5 thousand and $64.8 thousand, respectively, if only the counties of the five boroughs of Manhattan and Westchester 3 - 2 had been considered.