CRA RATINGS OF MASSACHUSETTS BANKS, CREDIT UNIONS, AND LICENSED MORTGAGE LENDERS IN 2013 MAHA's Twenty-Third Annual Report on How Well Lenders and Regulators Are Meeting Their Obligations Under the Community Reinvestment Act

Prepared for the

Massachusetts Affordable Housing Alliance 1803 Dorchester Avenue Dorchester MA 02124 mahahome.org by

Jim Campen Professor Emeritus of Economics University of Massachusetts/Boston [email protected]

March 2014 (released March 10; revised March 20)

INTRODUCTION AND SUMMARY OF MAJOR FINDINGS Since 1990, state and federal bank regulators have been required to make public their ratings of the performance of individual banks in serving the credit needs of local communities, in accordance with the provisions of the federal Community Reinvestment Act (CRA) and its Massachusetts counterpart. And since 1991, the Massachusetts Affordable Housing Alliance (MAHA) has issued annual reports offering a comprehensive listing and analysis of all CRA ratings of Massachusetts banks and credit unions. This is the twenty-third report in this annual series. Beginning three years ago, these reports also include information on the CRA-like ratings of licensed mortgage lenders issued by the state’s Division of Banks in accordance with its “Mortgage Lender Community Investment” (MLCI) regulation. As defined for this report, there were 169 “Massachusetts banks” as of December 31, 2013. This includes not only 148 banks that have headquarters in the state, but also 20 banks based elsewhere that have one or more branch offices in Massachusetts.1 Table A-1 provides a listing of the 169 Massachusetts banks and their current CRA ratings. (The 36 federally-chartered banks receive ratings only from their federal regulator; state-chartered banks receive ratings from both Massachusetts and federal regulators.)2 3 Banks that operate in more than one state receive separate federal CRA ratings for each state as well as an overall CRA rating; for such banks, this report uses the CRA rating for their Massachusetts operations rather than the overall rating.4 Table A-2 provides information on the 37 banks that have branches both inside and outside of Massachusetts; these banks are shown in italics in Table A-1. Table A-3 provides a listing of the current CRA ratings of the state’s 78 state-chartered credit unions. (The 114 federally-chartered credit unions based in Massachusetts are not covered by CRA.) Table A-4 provides a listing of all current CRA (MLCI) ratings of licensed mortgage lenders. Tables 1-8 present information about the distribution of the most recent CRA ratings of banks, credit unions, and licensed mortgage lenders as of year-end 2013; about the distribution of CRA ratings awarded during the calendar year 2013 and during earlier years; and about the number and distribution of

1

This report’s definition of “Massachusetts Banks” excludes ten trust companies that specialize in providing services to investors; these banks do not offer retail banking services and most of them have no deposits in their Massachusetts branches. 2 For at least the last two years, CRA ratings of state-chartered banks have almost always been the result of a joint examination by the state and the FDIC (resulting in a single performance evaluation with both agencies’ names on the cover) or of a concurrent examination by the state and the Fed (resulting in separate performance evaluations with the same exam date on the cover). The only exceptions during 2012 and 2013 were separate ratings of Millbury SB, Monson SB, and Wrentham Coop by the FDIC and of Greenfield Coop by the Fed. The state and federal ratings resulting from these joint or concurrent exams have always been the same during the last two years except in those relatively few cases where the state rating has been “High Satisfactory,” a rating not available to federal regulators who in every such case awarded the rating of “Satisfactory.” 3 Although the nine banks chartered by other states that have Massachusetts branches are subject to oversight by the state’s Division of Banks for their in-state activities, the Division has not yet awarded any CRA ratings to any of these banks. These nine banks are shown on a separate row in Table 4. 4 To be more precise, banks with branches in more than one state receive not only an overall CRA rating, but also (1) a separate rating for each multistate metropolitan statistical area (MSA) within which they have branches and (2) a separate rating for each state (the “state” rating excludes any part of the state covered by a multistate MSA rating). Since most of the Massachusetts activity of Bank of America, RBS Citizens, and Santander is within multistate MSAs (e.g., the Boston MA-NH MSA), their “Massachusetts” CRA ratings are based on evaluation of only a small portion of their activity within the state. Therefore, their ratings in this report are those for these multistate MSAs.

CRA ratings awarded annually by each of the federal bank regulators and by the state’s Division of Banks. Some of the notable findings contained in those tables may be summarized as follows: •

There were a total of 66 CRA ratings of Massachusetts banks in 2013 – 41 from federal regulators and 25 from the state. This was far fewer than the 100 ratings awarded in 2012 and was the second lowest in any year since CRA ratings first became public in 1991. (See Table 1.)

•

Of the 66 CRA ratings awarded to Massachusetts banks during 2013, almost one-quarter (24.2%) were “Outstanding.” This relatively high share of “Outstanding” ratings (the highest in the last six years) resulted from the fact that the “Outstanding” share for the OCC was 73% (8 of 11 banks); the “Outstanding” share for the other two federal regulators was 13% (4 of 30), while the share for the state was 16% (4 of 25). (See Tables 1 and 2.)

•

When each bank is classified by its most recent CRA rating, 22.2% of all banks had a most recent rating of “Outstanding” at year-end 2013, up slightly from 19.5% in the previous two years, but remaining far lower than the all-time high of 31.3% reached in 2007. Another 11.4% of banks had a most recent rating of “High Satisfactory,” and nearly two-thirds (64.7%) of all banks had a most recent rating of “Satisfactory.” Three banks (1.8%) had a most recent rating of “Needs to Improve”; OneUnited Bank is the only one of these based in Massachusetts. (See Table 3.)

•

The state’s ten biggest banks were all rated “Outstanding” in their most recent CRA exams. These ten banks, ranked by total deposits as reported by the FDIC for mid-2013, are: State Street, Bank of America, RBS Citizens, Santander, TD Bank, Eastern, Rockland Trust, Middlesex Savings, BNY Mellon, and People’s United.5 (See Table A-1 for ratings of all individual banks.)

•

When banks are classified, for each regulator, in terms of the year in which they most recently received a CRA rating, the data reveal that 60.3% of Massachusetts banks have received at least one CRA rating (federal and/or state) within the past two years and that only three banks have not received any CRA rating within the last five years. During the most recent five year period, six banks have not received a CRA rating from their federal regulator. Twelve in-state banks and all nine out-of-state state-chartered banks have not received a rating from the Division of Banks within the last five years.6 (See Table 4.)

•

The number of credit unions with “Outstanding” ratings fell from six to three (3.8% of the 78 current state-chartered credit unions), as HarborOne CU became a bank and Haverhill Fire Department CU and Leominster CU received “Satisfactory” ratings during 2013. No credit union has received a rating of less than “Satisfactory” since 1997. Nineteen ratings were awarded in 2013, sharply up from six in 2011 and seven in 2012. To provide a rating to every state-chartered credit union during a four-year period would require about twenty ratings per year. As of year-end 2013,

5

The Bank of New York Mellon (New York City) had $10.6B of deposits in Massachusetts and ranked sixth on the FDIC’s list. However, this bank is a wholesale bank whose CRA “assessment area” lies entirely within metropolitan New York and it is thus not counted as a Massachusetts bank for purposes of this report. BNY Mellon, an affiliated bank with headquarters in Pittsburgh, is counted as a Massachusetts bank. 6 Table 4 and the discussion in this paragraph provide one indication of the timeliness with which regulators are awarding CRA ratings. Ideally, the performance of each regulator would be compared to its own stated policy on the frequency of CRA examinations and ratings. However, this would be a complex task, beyond the scope of the present report. Complexity results from (1) the fact that mandated examination frequency depends on the asset size of the bank and on the bank’s previous rating (for the Fed and the FDIC, it also depends on the bank’s “Compliance Rating,” which is not public) and (2) the fact that the policies of the three federal regulators differ significantly among themselves, and from the policies of the DoB. The Division of Bank’s policy is in its Regulatory Bulletin 1.3-105. The Federal Reserve’s policy is contained in its Consumer Affairs Letters (CA 13-20). The FDIC’s policy is in Section II-11.1 of its Compliance Examination Manual. The OCC’s policy can be found by a Google search for “How often does the OCC conduct a CRA examination?”

twelve credit unions (15.4% of the total) had not received a CRA rating based on an exam dated within the last six years; One Twenty CU’s most recent exam is dated in 2001, St. Anne CU’s most recent exam is dated in 2004, and Tremont CU’s most recent exam is dated in 2005. (Tables 5, 6, and A-3.) •

Of the one hundred licensed mortgage lenders that qualified for coverage under the state’s Mortgage Lender Community Investment (MLCI) regulation on the basis of their 2012 lending,7 only eight were awarded ratings in 2013 and only 41 had ever received ratings since the initial ratings were awarded in the final quarter of 2009. This is not consistent with the Division of Banks’ stated policy of examining all licensed mortgage lenders “at least once every 48 months.”8 One lender has a rating of “High Satisfactory,” thirty-six lenders have ratings of “Satisfactory,” and four lenders have ratings of “Needs to Improve.” Of the 2013 ratings, seven were “Satisfactory” and one was “Needs to Improve.” Of the top six licensed mortgage lenders, as ranked by number of loans reported in 2012 HMDA data, only Mortgage Network, ranked fourth, has received a rating. However, twelve of the fourteen lenders ranked seventh through twentieth have been rated. (See Tables 7, 8, and A-4).

In addition to these findings, all of which summarize information contained in the tables that follow, it is worth noting one significant shortcoming in the performance of a regulatory agency in providing accurate and timely information: •

7

For the second time in two years, the OCC went several months without issuing monthly News Releases with lists of the CRA ratings that “became public” during the previous month. First, there was a six-month gap when no such lists were released between August 2, 2011 and March 1, 2012. Second, after the lists due in early June and July 2013 were belatedly issued in mid-August, there was a another long gap until the list due in early July was finally released more than seven months late, on February 12, 2014.9 Within the next month, the OCC released six more monthly lists and has become current. During these long gaps, there was no way for the public to know what CRA ratings by the OCC might have “become public.”

Author’s calculation from 2012 HMDA data, which showed that 100 licensed mortgage lenders (LMLs) made fifty or more mortgage loans in the state (66 additional LMLs reported between 1 and 49 loans). An unknown number of these lenders are no longer licensed to make loans in Massachusetts. Table A-4 shows that of the 41 currently-licensed mortgage lenders that have been awarded ratings under MLCI, three did not report any loans in Massachusetts in 2012 and one more reported fewer than fifty loans. Table 7 includes ratings awarded in previous years to LMLs that are no longer licensed in the state, but Tables 8 and A-4 include only LMLs licensed as of January 2014. 8 This policy is in the Division’s Regulatory Bulletin 1.3-105, Section II.A. An exception is provided for mortgage lenders who receive a rating of “Outstanding” or “High Satisfactory”; the next examination for these lenders should be no sooner than 60 months following the previous exam. The Division of Banks’ online “CRA for Mortgage Lenders – Examination Schedule” indicated, as of late January 2014, that six licensed mortgage lenders were “tentatively scheduled” for examinations during the second quarter of 2013 and six more during the third quarter of 2013. Although none of these twelve lenders was awarded a public rating by the end of 2013, this may indicate that there will an increased number of ratings in 2014. 9 When the OCC is operating on schedule, it issues a “News Release” early in the month, announcing the ratings that became publicly available during preceding month and including a link to a list of the banks and their ratings. For example, the News Release of April 1, 2013 announced that the OCC had “released a list of Community Reinvestment Act (CRA) performance evaluations that became public during the period of March 1, 2013 through March 29, 2013.” There was a news release on September 11, 2013 announcing the list covering July, but the link to the list itself was inactive until February 2014. The OCC became current with a news release of March 12, 2014 that included a link to the list of ratings that became public during February 2014.

For Additional Information: •

A great deal of information on the CRA (Community Reinvestment Act) in general, and on the CRA evaluation/examination/rating system in particular is readily available on the web sites of the state’s Division of Banks (www.state.ma.us/dob) and of the federal bank regulators: the Federal Deposit Insurance Corporation (www.fdic.gov); the Office of the Comptroller of the Currency (www.occ.treas.gov); and the Federal Reserve (www.federalreserve.gov).

•

The Mortgage Lender Community Investment (MLCI) regulation (209 CMR 54.00), as well as a list of the MLCI ratings made public so far (with links to the performance evaluations), is available at the Division of Banking’s website: www.mass.gov/dob.

•

Almost all of the Performance Evaluations for Massachusetts banks, credit unions, and licensed mortgage lenders are available in their entirety at the websites of the regulators that prepared them, where they can be read on-line, down-loaded, or printed out. A fourth federal bank regulator, the Office of Thrift Supervision, was merged into the OCC in mid-2011; the CRA section of the OCC website provides a link to the former OTS website for access to its database of OTS ratings and performance evaluations.

March 20 Revisions: The present version of this report includes three changes from the original report released on March 10: (1) the OCC has become current in releasing its monthly lists of CRA ratings and its newly-available list for December 2014 included the rating of one Massachusetts bank (Rollstone Bank); (2) the Fed is now correctly shown as the federal regulator of six state-chartered banks who recently became “state member” banks; and (3) Mortgage Financial is now correctly shown in Table 4 as ranking 19th among the state’s LMLs in 2012. The revisions include changes to the text as well as to Tables 1, 2, 4, A-1, and A-4.

TABLE 1 NUMBER & PERCENT OF CRA RATINGS GIVEN TO MASSACHUSETTS BANKS THAT WERE "OUTSTANDING" OR BELOW "SATISFACTORY" -- 1991-2013

Year 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Number of Ratings Federal Mass. Total 56 54 110 88 109 197 97 55 152 137 38 175 120 119 239 106 98 204 88 71 159 82 77 159 83 78 161 48 50 98 39 38 77 46 37 83 55 23 78 69 30 99 53 41 94 40 32 72 35 19 54 57 37 94 50 25 75 44 26 70 32 34 66 56 44 100 41 25 66

% Outstanding % Below Satisfactory* Federal Mass. Total Federal Mass. Total 5.4% 3.7% 4.5% 17.9% 20.4% 19.1% 10.2% 12.8% 11.7% 19.3% 18.3% 18.8% 15.5% 12.7% 14.5% 8.2% 7.3% 7.9% 10.2% 23.7% 13.1% 7.3% 2.6% 6.3% 24.2% 24.4% 24.3% 3.3% 0.8% 2.1% 32.1% 34.7% 33.3% 1.0% 1.0% 1.0% 28.4% 29.6% 28.9% 1.1% 0.0% 0.6% 25.6% 24.7% 25.2% 0.0% 0.0% 0.0% 16.9% 25.6% 21.1% 2.4% 0.0% 1.2% 29.2% 20.0% 24.5% 0.0% 0.0% 0.0% 15.4% 15.8% 15.6% 2.6% 2.6% 2.6% 15.2% 21.6% 18.1% 0.0% 0.0% 0.0% 18.2% 34.8% 23.1% 0.0% 0.0% 0.0% 24.6% 26.7% 25.3% 0.0% 0.0% 0.0% 35.8% 26.8% 31.9% 1.9% 0.0% 1.1% 40.0% 28.1% 34.7% 0.0% 0.0% 0.0% 40.0% 26.3% 35.2% 5.7% 0.0% 3.7% 17.5% 13.5% 16.0% 0.0% 0.0% 0.0% 12.0% 12.0% 12.0% 2.0% 0.0% 1.3% 18.2% 15.4% 17.1% 2.3% 0.0% 1.4% 21.9% 20.6% 21.2% 3.1% 2.9% 1.5% 21.4% 18.2% 20.0% 1.8% 0.0% 1.0% 29.3% 16.0% 24.2% 5.1% 0.0% 3.1%

* Since 1993, all ratings below "Satisfactory" have been "Needs to Improve."

TABLE 2 PUBLIC CRA RATINGS OF MASSACHUSETTS BANKS BY REGULATOR AND RATING, 1993-2013 Out

OCC Sat NI

All

OTS or Fed* Out Sat NI All

Out

FDIC Sat NI

All

MASS Out HSat Sat NI

All

A. Numbers of Ratings 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

2 0 1 1 2 0 2 0 0 0 0 0 0 0 2 1 1 0 1 3 8

12 8 6 6 6 2 2 1 1 1 2 3 4 2 1 2 5 3 1 5 3

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

14 8 7 7 8 2 4 1 1 1 2 3 4 2 3 3 6 3 2 8 11

0 1 0 4 1 3 2 0 1 0 0 2 3 3 3 1 1 4 2 2 2

12 10 9 8 5 6 6 1 5 3 3 5 3 2 4 5 4 6 2 4 3

2 1 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1

14 12 10 12 7 9 8 1 6 3 3 7 6 5 7 6 5 11 4 6 6

13 13 28 29 22 18 10 14 5 7 8 14 15 12 9 8 3 4 4 7 2

50 95 72 57 51 53 59 32 26 35 40 44 26 20 14 38 33 24 21 34 21

6 9 3 1 0 0 2 0 1 0 0 0 1 0 2 0 1 0 0 1 1

69 117 103 87 73 71 71 46 32 42 48 58 42 32 25 46 37 28 25 42 24

7 9 29 34 21 19 20 10 6 8 8 8 7 9 5 4 3 4 7 8 4

* * * * 5 19 15 6 14 10 7 5 4 4 5 10 6 5 8 8 3

44 28 89 63 45 39 43 34 17 19 8 17 30 19 9 23 16 17 18 28 18

4 1 1 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 1 0 0

13% 24% 24% 35% 30% 25% 26% 20% 16% 22% 35% 27% 17% 28% 26% 11% 12% 15% 21% 18% 16%

0% 0% 0% 0% 7% 25% 19% 12% 37% 27% 30% 17% 10% 13% 26% 27% 24% 19% 24% 18% 12%

80% 74% 75% 64% 63% 51% 55% 68% 45% 51% 35% 57% 73% 59% 47% 62% 64% 65% 53% 64% 72%

7% 3% 1% 1% 0% 0% 0% 0% 3% 0% 0% 0% 0% 0% 0% 0% 0% 0% 3% 0% 0%

B. Percentage Distribution of Ratings by Each Regulator in Each Year 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2012

14% 0% 14% 14% 25% 0% 50% 0% 0% 0% 0% 0% 0% 0% 67% 33% 17% 0% 50% 38% 73%

86% 100% 86% 86% 75% 100% 50% 100% 100% 100% 100% 100% 100% 100% 33% 67% 83% 100% 50% 63% 27%

0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

0% 8% 0% 33% 14% 33% 25% 0% 17% 0% 0% 29% 50% 60% 43% 17% 20% 36% 50% 33% 33%

86% 14% 83% 8% 90% 10% 67% 0% 71% 14% 67% 0% 75% 0% 100% 0% 83% 0% 100% 0% 100% 0% 71% 0% 50% 0% 40% 0% 57% 0% 83% 0% 80% 0% 55% 9% 50% 0% 67% 0% 50% 17%

19% 11% 27% 33% 30% 25% 14% 30% 16% 17% 17% 24% 36% 38% 36% 17% 8% 14% 16% 17% 8%

72% 81% 70% 66% 70% 75% 83% 70% 81% 83% 83% 76% 62% 63% 56% 83% 89% 86% 84% 81% 88%

9% 8% 3% 1% 0% 0% 3% 0% 3% 0% 0% 0% 2% 0% 8% 0% 3% 0% 0% 2% 4%

Notes: The rating of "High Satisfactory" became available to Mass. regulators -- but not to federal regulators -- in mid-1997. No Massachusetts bank has received a rating of "Substantial NonCompliance" since 1992. *

Ratings shown through 2010 are those of the OTS, which also gave one rating ("Sat") in 2011 before mergining into OCC. Ratings shown for 2011 and later are those of the Fed, which gave between 0 and 2 ratings per year before 2011.

55 38 119 98 71 77 78 50 38 37 23 30 41 32 19 37 25 26 34 44 25

TABLE 3 DISTRIBUTION OF MOST RECENT CRA RATINGS OF MASSACHUSETTS BANKS BY NUMBER OF RANKINGS AND PERCENT, YEAR-END 1993-2013 Date 1993

1995

1997

1999

2001

2003

2005

2006

2007

2008

2009

2010

2011

2012

2013

Active Banks

286

257

245

228

220

210

194

195

185

179

176

171

165

159

169

Rated Banks

262

257

243

227

219

207

194

192

182

177

173

169

164

159

167

"Outstanding"

32

57

70

57

47

44

51

54

57

49

41

35

32

31

37

n/a

n/a

5

21

21

17

6

7

11

7

20

22

24

21

19

"High Satisfactory"# "Satisfactory"

198

196

168

147

150

146

136

130

112

119

112

111

106

106

108

Below "Satisfactory"

32

4

0

2

1

0

1

1

2

2

0

1

2

1

3

% "Outstanding" 12.2% 22.2% 28.8% 25.1% 21.5% 21.3% 26.3% 28.1% 31.3% 27.7% 23.7% 20.7% 19.5% 19.5% 22.2% % "High Satisfactory"#

n/a

n/a 2.1% 9.3% 9.6% 8.2% 3.1% 3.6% 6.0% 4.0% 11.6% 13.0% 14.6% 13.2% 11.4%

% "Satisfactory" 75.6% 76.3% 69.1% 64.8% 68.5% 70.5% 70.1% 67.7% 61.5% 67.2% 64.7% 65.7% 64.6% 66.7% 64.7% % Below "Satisfactory" 12.2% 1.6% 0.0% 0.9% 0.5% 0.0% 0.5% 0.5% 1.1% 1.1% 0.0% 0.6% 1.2% 0.6% 1.8% Note: For increased legibility, the columns for even-numbered years between 1994 and 2004 are not shown in this table. # The rating of "High Satisfactory," first awarded in mid-1997, is available only from Mass. For the 19 banks with a most recent rating of "High Satisfactory," 17 had federal ratings of "Satisfactory" in concurrent federal/state exams; if concurrent exams led to different ratings, the higher is regarded as "most recent."

TABLE 4 YEAR OF MOST RECENT CRA RATINGS OF MASSACHUSETTS BANKS BY REGULATOR AND OVERALL, AS OF DECEMBER 31, 2013

Regulator FED OCC FDIC MASS-In MASS-Out All Banks

Banks 12/31/13 28 34 107 126 9 169

Last Rated in 2013 # % 7 25.0% 11 32.4% 28 26.2% 25 19.8% 0 0.0% 46 27.2%

Last Rated in 2012 # % 10 35.7% 7 20.6% 38 35.5% 43 34.1% 0 0.0% 56 33.1%

Last Rated Last Rated Last Rated Not in Last in 2011 in 2010 in 2009 5 Years # % # % # % # % 6 21.4% 4 14.3% 1 3.6% 0 0.0% 2 5.9% 8 23.5% 4 11.8% 2 5.9% 19 17.8% 8 7.5% 10 9.3% 4 3.7% 27 21.4% 12 9.5% 7 5.6% 12 9.5% 0 0.0% 0 0.0% 0 0.0% 9 100% 31 18.3% 20 11.8% 13 7.7% 3 1.8%

Note: Mass-In banks are Mass-chartered; Mass-Out banks are chartered by other states with branches in Mass.

TABLE 5 DISTRIBUTION OF CRA RATINGS GIVEN TO MASS. CREDIT UNIONS DURING EACH YEAR, 1991-2013 Year 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Total 4 24 11 72 62 65 50 63 38 29 25 25 21 18 10 13 10 29 16 10 6 7 19

Number of Ratings Awarded OUT HI SAT SAT 0 NA 3 0 NA 7 0 NA 9 1 NA 51 3 NA 48 2 NA 60 3 0 47 2 3 58 1 2 35 4 1 24 1 5 19 0 1 24 4 2 15 0 2 16 0 0 10 2 0 11 1 2 7 2 3 24 1 3 12 0 5 5 0 0 6 1 1 5 1 3 15

Distribution of Ratings During Year OUT HI SAT SAT NI 0.0% NA 75.0% 25.0% 0.0% NA 29.2% 70.8% 0.0% NA 81.8% 18.2% 1.4% NA 70.8% 27.8% 4.8% NA 77.4% 17.7% 3.1% NA 92.3% 4.6% 6.0% 0.0% 94.0% 0.0% 3.2% 4.8% 92.1% 0.0% 2.6% 5.3% 92.1% 0.0% 13.8% 3.4% 82.8% 0.0% 4.0% 20.0% 76.0% 0.0% 0.0% 4.0% 96.0% 0.0% 19.0% 9.5% 71.4% 0.0% 0.0% 11.1% 88.9% 0.0% 0.0% 0.0% 100.0% 0.0% 15.4% 0.0% 84.6% 0.0% 10.0% 20.0% 70.0% 0.0% 6.9% 10.3% 82.8% 0.0% 6.3% 18.8% 75.0% 0.0% 0.0% 50.0% 50.0% 0.0% 0.0% 0.0% 100.0% 0.0% 14.3% 14.3% 71.4% 0.0% 5.3% 15.8% 78.9% 0.0%

NI 1 17 2 20 11 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

One of the state's 79 state-chartered credit unions has its most recent rating based on an exam dated in 2001; one more had its most recent exam dated in 2004; one in 2005; three in 2006; six in 2007; and twenty in 2008.

TABLE 6 DISTRIBUTION OF CURRENT CRA RATINGS OF MASSACHUSETTS CREDIT UNIONS BY NUMBER OF RANKINGS AND PERCENT, YEAR-END 1993-2013 Date 1993 Rated CUs

29

1995

1997

1999

2001

2003

2005

2006

2007

2008

2009

2010

2011

2012

2013

123

122

117

111

108

101

98

96

93

91

90

87

84

78

"Outstanding"

0

2

6

7

7

7

7

6

6

7

7

6

6

6

3

"High Satisfactory"#

n/a

n/a

0

6

8

10

10

10

10

10

12

15

14

14

15

"Satisfactory"

14

98

113

104

96

91

84

82

80

76

72

69

67

64

60

Below "Satisfactory"

15

23

3

0

0

0

0

0

0

0

0

0

0

0

0

% "Outstanding"

0.0%

1.6%

4.9%

6.0%

6.3%

6.5%

6.9%

6.1%

6.3%

7.5%

7.7%

6.7%

6.9%

7.1%

3.8%

% "High Satisfactory"#

n/a

n/a

0.0%

5.1%

7.2%

9.3%

9.9% 10.2% 10.4% 10.8% 13.2% 16.7% 16.1% 16.7% 19.2%

% "Satisfactory" 48.3% 79.7% 92.6% 88.9% 86.5% 84.3% 83.2% 83.7% 83.3% 81.7% 79.1% 76.7% 77.0% 76.2% 76.9% % Below "Satisfactory" 51.7% 18.7%

2.5%

0.0%

0.0%

0.0%

0.0%

0.0%

0.0%

0.0%

Note: For increased legibility, the columns for even-numbered years between 1994 and 2004 are not shown in this table. # The rating of "High Satisfactory" was not an option until mid-1997.

0.0%

0.0%

0.0%

0.0%

0.0%

TABLE 7 RATINGS^ OF LICENSED MORTGAGE LENDERS AWARDED, 2009-2013 Year 2009* 2010 2011 2012 2013

Total 6 14 16 5 8

Out 0 0 0 0 0

Number of Ratings HS Sat NI 0 5 0 1 12 1 0 15 1 0 4 1 0 7 1

SNC 1 0 0 0 0

Out 0.0% 0.0% 0.0% 0.0% 0.0%

Percent of Ratings HS Sat NI 0.0% 83.3% 0.0% 7.1% 85.7% 7.1% 0.0% 93.8% 6.3% 0.0% 80.0% 20.0% 0.0% 87.5% 12.5%

SNC 16.7% 0.0% 0.0% 0.0% 0.0%

* 2009 was a partial year -- October to December only. ^ Table does not include three exams that resulted in consent orders rather than ratings -- see Table A-4. Note: a list of individual lenders and their ratings, together with links to their performance evaluations, is available at: www.mass.gov/dob. Click on: "Loans & Mortgages," then "CRA for Mortgage Lenders."

TABLE 8 CURRENT RATINGS OF LICENSED MORTGAGE LENDERS, YEAREND 2013

Year 2013

Total 41

Number of Lenders with Rating Out HS Sat NI 0 1 36 4

SNC 0

Out 0.0%

Percent of Ratings HS Sat NI 2.4% 87.8% 9.8%

SNC 0.0%

TABLE A-1 CURRENT CRA RATINGS OF MASS. BANKS AS OF DEC. 31, 2013 (page 1 of 4) Mass Mass

Mass

Mass

Fed

Fed

Fed

Fed

Reg? Rating

List

ExamDate

Reg

Rating

List

ExamDate

SAT

Dec-13

08/26/13

Fed

SAT

Dec-13

08/26/13

SAT

Mar-09

12/08/08

FDIC

SAT

May-09

OCC

SAT

Jun-11

03/30/11

FDIC

SAT

Oct-11

03/30/11

Dec-13

07/15/13

FDIC

SAT

Feb-14

07/15/13

Apr-12

01/17/12

Fed

SAT

Apr-12

OCC

OUT

Oct-10

04/10/06

FDIC

SAT

Jul-11

12/23/10

Feb-12

08/22/11

FDIC

SAT

Mar-12

08/22/11

Jan-11

10/05/10

Fed

SAT

Dec-10

Bank

City/Town

Abington Bank

Abington

yes

Adams Community Bank*

Adams

yes

Admirals Bank^

Boston

no

Athol SB

Athol

yes

HS

Sep-11

Avidia Bank

Hudson

yes

SAT

Avon Coop Bank

Avon

yes

SAT

Bank of America

Charlotte NC

no

Bank of Canton

Canton

yes

HS

Sep-06

Bank of Cape Cod

Hyannis

yes

SAT

Bank of Easton

North Easton

yes

SAT

Bank of New England

Salem NH

yes#

BankFive

Fall River

yes

BankGloucester

Gloucester

Barre SB

Barre

Bay State SB

FDIC

NI May-13

OUT

Aug-12

03/26/12

FDIC

OUT

yes

HS

May-11

02/14/11

FDIC

yes

SAT

Sep-13

05/29/13

FDIC

Worcester

yes

OUT

Jan-12

05/09/11

BayCoast Bank*

Fall River

yes

HS

Apr-11

11/15/10

Beal Bank USA**

Las Vegas NV yes#

Belmont SB

Belmont

yes

SAT

Mar-12

08/10/11

Berkshire Bank

Pittsfield

yes

SAT

May-13

Beverly Coop Bank

Beverly

yes

SAT

Blue Hills Bank*

Boston

yes

SAT

BNY Mellon, NA

Pittsburgh PA

no

Boston Private B&T

Boston

yes

OUT

Feb-12

Braintree Coop Bank

Braintree

yes

SAT

Sep-10

Bridgewater SB^^

Bridgewater

yes

SAT

Jul-11

Bristol County SB

Taunton

yes

HS

Sep-13

Brookline Bank^^

Brookline

yes

Cambridge SB

Cambridge

yes

OUT

Sep-11

04/25/11

Cambridge Trust Co

Cambridge

yes

SAT

Jun-11

01/25/11

Canton Coop Bank

Canton

yes

SAT

Jun-12

02/27/12

Cape Ann SB

Glouscester

yes

HS

Oct-12

Cape Cod Coop Bank

Yarmouth Port yes

SAT

Cape Cod Five Cents SB

Harwich Port

yes

OUT

Cathay Bank

Los Angeles CA

yes#

Century B&T

Somerville

yes

SAT

Nov-11

Charles River Bank

Medway

yes

SAT

Feb-13

Chelsea Bank

Chelsea

yes

HS

Feb-10

11/30/09

Chicopee SB

Chicopee

yes

OUT

Aug-13

03/04/13

CitiBank, NA

Souix Falls SD no

Clinton SB

Clinton

yes

SAT

Mar-13

Colonial Coop Bank

Gardner

yes

HS

Jul-07

Colonial FSB

Quincy

no

Commerce B&T

Worcester

yes

SAT

Nov-11

Commonwealth Coop Bank

Boston

yes

SAT

Cooperative Bank, The

Boston

yes

SAT

12/08/08 03/31/11

01/17/12 03/31/09

10/04/10 12/03/12

Oct-12

03/26/12

SAT

Mar-09

10/17/07

SAT

Nov-13

05/29/13

FDIC

OUT

Feb-12

FDIC

SAT May-11

11/15/10

FDIC

SAT

Feb-14

07/29/13

FDIC

SAT

May-12

09/24/12

FDIC

SAT

Jun-13

Jul-12

02/13/12

FDIC

SAT

Aug-12

Oct-12

05/29/12

FDIC

SAT

OCC

OUT

08/15/11

FDIC

OUT Mar-12

05/24/10

FDIC

SAT

12/13/10

Fed

SAT

Aug-11

04/01/13

FDIC

SAT

Oct-13

Fed

SAT

Apr-12

01/23/12

FDIC

SAT

Nov-11

04/25/11

FDIC

SAT

Aug-11

01/25/11

Fed

SAT

Jun-12

02/27/12

06/04/12

FDIC

SAT

Dec-12

06/04/12

Feb-12

05/16/11

FDIC

SAT

Mar-12

05/16/11

Mar-11

09/17/10

Dec-12 none Nov-08

05/09/11

08/10/11 09/24/12 02/13/12 05/29/12 04/27/09 08/15/11 06/23/08 12/13/10 04/01/13

FDIC

OUT

Apr-11

FDIC

SAT

Jul-13

09/17/10

06/06/11

FDIC

SAT

Sep-08

11/21/07

10/01/12

Fed

SAT

Jan-13

10/01/12

Fed

SAT

Mar-10

11/30/09

FDIC

OUT

Oct-13

OCC

OUT

none

10/15/12

FDIC

SAT

Apr-13

10/15/12

03/12/07

FDIC

SAT

Mar-10

09/10/09

OCC

OUT

Mar-13

12/26/12

05/02/11

FDIC

SAT

Dec-11

04/21/11

Jul-13

04/22/13

FDIC

SAT

Sep-13

04/22/13

Aug-10

03/08/10

FDIC

SAT

Oct-10

03/08/10

09/04/12

03/04/13 07/26/10

TABLE A-1 CURRENT CRA RATINGS OF MASS. BANKS AS OF DEC. 31, 2013 (page 2 of 4) Mass Mass

Mass

Mass

Fed

Fed

Fed

Fed

Reg? Rating

List

ExamDate

Reg

Rating

List

ExamDate

Jan-13

07/24/12

FDIC

SAT

Feb-13

07/24/12

SAT

Sep-12

03/29/12

FDIC

SAT

Oct-12

03/29/12

SAT

Mar-02

06/20/11

FDIC

SAT

Apr-12

06/20/11

yes

HS

Dec-12

07/02/12

FDIC

SAT

Jan-13

07/02/12

Boston

yes

SAT

Jun-12

11/17/11

FDIC

SAT

Aug-12

11/17/11

Cambridge

yes

SAT

Oct-10

06/01/10

Fed

SAT

Dec-10

Fed

SAT

Jun-11

FDIC

OUT

Bank

City/Town

Country BfS

Ware

yes

HS

Dean Coop Bank

Franklin

yes

Dedham Inst for Savings

Dedham

yes

Eagle Bank

Everett

East Boston SB East Cambridge SB^^ East West Bank

Pasadena CA yes#

Eastern Bank

Boston

yes

OUT

Dec-11

06/20/11

Easthampton SB^^

Easthampton

yes

SAT

Jun-12

12/19/11

Edgartown NB

Edgartown

no

Enterprise B&T

Lowell

yes

SAT

Jul-11

Equitable Coop Bank

Lynn

yes

SAT

Everett Coop Bank

Everett

yes

SAT

Family Federal Savings

Fitchburg

no

FamilyFirst Bank

Ware

yes

SAT

Jan-09

Fidelity Coop Bank

Fitchburg

yes

SAT

Nov-13

First Commons Bank

Newton

no

OCC

First FSB of Boston^

Boston

no

OCC

First Ipswich Bank^^

Ipswich

yes

Fed

SAT

First Niagara Bank, NA

Buffalo NY

no

OCC

First Republic Bank

San Francisco yes#

FDIC

SAT

Jun-12

10/31/11

First Trade Union SB

Boston

no

OCC

SAT

Feb-12

10/31/11

Florence SB

Florence

yes

FDIC

SAT

Jan-12

06/27/11

Foxboro Federal Savings

Foxboro

no

OCC

SAT

Aug-13

06/07/13

Georgetown Bank^

Georgetown

no

OCC

SAT

Apr-10

01/25/10

Granite SB

Rockport

yes

SAT

Sep-06

10/06/06

FDIC

SAT

Dec-09

06/09/09

Greenfield Coop Bank^^

Greenfield

yes

OUT

Aug-12

03/30/12

Fed

OUT

Oct-12

03/30/12

Greenfield SB

Greenfield

SAT

May-12

08/08/11

HS

06/01/10 10/25/10

Jan-12

06/20/11 12/19/11

Fed

SAT

Jul-12

OCC

SAT

Apr-09

11/01/10

FDIC

SAT

Sep-11

Nov-13

07/15/13

FDIC

SAT

Jan-14

07/15/13

Mar-13

10/15/12

FDIC

SAT

Apr-13

10/15/12

OCC

SAT

Oct-13

08/05/13

09/19/08

FDIC

SAT

Nov-11

04/04/11

04/15/13

FDIC

SAT

Jan-14

04/15/13

SAT

Aug-12

05/29/12

OUT

May-10

02/08/10

Jul-11

01/03/11

Jan-12

06/27/11

12/09/08 11/01/10

[prior exam: no MA branches]

yes

OUT

Sep-08

02/19/08

FDIC

HarborOne Bank[CU until 7/2013]@ Brockton

yes

OUT

Jan-09

08/25/08

FDIC

Hampden Bank

Springfield

yes

OUT

Apr-12

08/15/11

FDIC

OUT

Apr-12

08/15/11

Haverhill Bank

Haverhill

yes

SAT

Oct-09

06/01/09

FDIC

SAT

Dec-09

06/01/09

Hingham Inst for Savings

Hingham

yes

SAT

Dec-12

03/30/12

FDIC

SAT

Dec-12

03/30/12

Holbrook Coop Bank

Holbrook

yes

SAT

May-06

02/21/06

FDIC

SAT

Jul-09

02/24/09

Hometown Bank

Webster

yes

SAT

Jul-06

05/02/06

FDIC

SAT

Feb-10

03/16/10

Inst for Savings

Newburyport

yes

SAT

Jun-12

08/15/11

FDIC

SAT

Mar-12

08/15/11

Leader Bank, NA

Arlington

no

OCC

SAT

Jun-10

03/16/10

Lee Bank

Lee

yes

FDIC

SAT

Dec-11

05/17/11

Lenox NB

Lenox

no

OCC

SAT

Sep-13

07/15/13

Lowell Five Cents SB

Lowell

yes

SAT

Mar-12

10/05/11

FDIC

SAT

Apr-12

Mansfield Coop Bank

Mansfield

yes

SAT

Jun-12

12/14/11

FDIC

SAT

Jul-12

12/14/11

Marblehead Bank

Marblehead

yes

OUT

Apr-09

02/17/09

Fed

OUT

May-09

02/17/09

Marlborough SB

Marlborough

yes

SAT

Jul-13

02/15/13

FDIC

SAT

Aug-13

02/15/13

Martha's Vineyard SB

Edgartown

yes

OUT

Sep-10

04/30/10

FDIC

OUT

Oct-10

04/30/10

Mechanics Coop Bank

Taunton

yes

HS

May-11

01/24/11

FDIC

SAT

Jul-11

01/24/11

Meetinghouse Bank

Boston

yes

SAT

Aug-05

05/13/05

FDIC

SAT

Jun-09

01/05/09

SAT

Nov-11

05/31/11

10/05/11

TABLE A-1 CURRENT CRA RATINGS OF MASS. BANKS AS OF DEC. 31, 2013 (page 3 of 4) Mass Mass

Mass

Mass

Fed

Fed

Fed

Fed

Reg? Rating

List

ExamDate

Reg

Rating

List

ExamDate

SAT

Apr-09

01/22/09

FDIC

yes

SAT

Jun-13

02/06/13

FDIC

SAT Aug-13

yes

SAT

Apr-07

12/28/06

FDIC

SAT

Oct-08

06/30/08

OCC

SAT

Sep-12

06/18/12

FDIC

OUT

Oct-10

11/30/09

no

OCC

OUT

Feb-13

no

OCC

OUT

Aug-13

03/11/13

Millbury

no

OCC

SAT

Jul-09

03/04/09

Millbury SB

Millbury

yes

SAT

Sep-10

06/07/10

FDIC

SAT

Apr-13

11/13/12

Monson SB

Monson

yes

SAT

Nov-11

12/20/10

FDIC

SAT

Nov-13

06/24/13

MountainOne Bank*

North Adams

yes

SAT

Aug-12

12/30/11

FDIC

SAT

Sep-12

12/30/11

Mutual Bank^^

Whitman

yes

Fed

OUT

Mar-13

10/29/12

MutualOne Bank*

Framingham

yes

FDIC

SAT

Nov-12

04/23/12

National Grand Bank

Marblehead

no

OCC

SAT

Jan-10

08/24/09

NBT Bank, NA

Norwich NY

no

OCC

[prior exam: no MA branches]

Needham Bank

Needham

yes

Newburyport Five Cents SB

Newburyport

North Brookfield SB^^

No.Brookfield

North Cambridge Coop Bank

Bank

City/Town

Melrose Coop Bank

Melrose

yes

Merrimac SB

Merrimac

Methuen Coop Bank

Methuen

Middlesex Fed Savings, FA

Somerville

no

Middlesex SB

Natick

yes

Milford Federal S&L

Milford

Milford NB

Milford

Millbury NB

OUT

SAT

Aug-10

Oct-12

11/30/09

04/23/12

SAT

Apr-13

12/03/12

Fed

yes

HS

Oct-12

06/04/12

yes

SAT

Nov-10

06/30/10

Cambridge

yes

SAT

Apr-10

North Easton SB

North Easton

yes

SAT

North Middlesex SB

Ayer

yes

North Shore Bank

Peabody

yes

Northampton Coop Bank

Northampton

yes

SAT

Northeast Community Bank^

White Plains NY

yes#

Northern B&T

Woburn

Northern Trust Co.

Chicago IL

yes#

Northmark Bank

N. Andover

yes

SAT

Aug-12

Norwood Coop Bank

Norwood

yes

SAT

Sep-10

Nuvo B&T

Springfield

yes

SAT

Sep-13

OneUnited Bank

Boston

yes

NI

Dec-11

Patriot Community Bank ^^

Woburn

yes

SAT

Aug-11

Pentucket Bank

Haverhill

yes

HS

Peoples Bank

Holyoke

yes

HS

Peoples Federal SB^

Boston

SAT

Jun-09

01/22/09 02/06/13

11/26/12

SAT

May-13

FDIC

SAT

Dec-12

Fed

SAT

Jan-11

06/30/10

01/11/10

FDIC

SAT

Jun-10

01/11/10

Sep-11

03/14/11

FDIC

SAT

Oct-11

03/14/11

HS

Feb-12

09/06/11

FDIC

SAT

Apr-12

09/06/11

SAT

Aug-13

03/14/13

FDIC

SAT

Oct-13

03/14/13

Dec-12

08/13/12

Fed

SAT

Dec-12

08/13/12

FDIC

OUT

FDIC

SAT

Apr-11

Fed

NI

Oct-13

03/19/12

FDIC

SAT

Oct-12

03/19/12

05/17/10

FDIC

SAT

Nov-10

05/17/10

05/29/13

FDIC

SAT

10/04/10

FDIC

NI

03/21/11

Fed

SAT

Jan-13

09/10/12

FDIC

SAT Mar-13

Jul-12

11/07/11

FDIC

SAT

Jul-12

no

OCC

OUT

May-11

People's United Bank^

Bridgeport CT no

OCC

OUT

Sep-10

Pilgrim Bank

Cohasset

yes

SAT

Apr-11

02/16/10

FDIC

SAT

Jul-11

Pittsfield Coop Bank

Pittsfield

yes

HS

Dec-08

09/17/08

FDIC

SAT

Feb-09

Provident Bank

Amesbury

yes

SAT

Sep-10

05/10/10

FDIC

SAT

Nov-10

05/10/10

Randolph SB

Randolph

yes

SAT

Apr-12

07/19/11

FDIC

SAT

Apr-12

07/19/11

RBS Citizens Bank

Providence RI

no

OCC

OUT

Apr-13

04/03/10

Reading Coop Bank

Reading

yes

SAT

Jan-12

09/12/11

Fed

SAT

Dec-11

09/12/11

Rockland Trust Co

Rockland

yes

OUT

Mar-12

12/27/10

FDIC

OUT

Apr-12

12/27/10

Rockport NB

Rockport

no

OCC

SAT

Jul-09

04/06/09

Rollstone B&T ^

Fitchburg

no

OCC

OUT

Dec-13

08/12/13

Sage Bank*

Lowell

yes

FDIC

SAT

Aug-11

01/18/11

yes

SAT

SAT

Feb-11

Jun-11

09/30/10

01/18/11

12/03/12 06/04/12

[2011] 02/22/11

Nov-13 Jan-12 Oct-11

09/30/10 06/25/12

05/29/13 10/04/10 03/21/11 09/10/12 11/07/11 02/14/11 10/05/09 02/16/10 09/17/08

TABLE A-1 CURRENT CRA RATINGS OF MASS. BANKS AS OF DEC. 31, 2013 (page 4 of 4) Bank

City/Town

Mass Mass Reg? Rating

Salem Coop Bank

Salem NY

yes#

Salem Five Cents SB

Salem

Salisbury B&T

Lakeville CT

Santander Bank *

Mass List

Mass ExamDate

Jun-13

01/14/13

Fed Reg

Fed Rating

Fed List

Fed ExamDate

FDIC

SAT

Jan-14

FDIC

SAT

Aug-13

yes#

FDIC

SAT

Pennsylvania

no

OCC

Saugus Bank

Saugus

yes

SAT

Feb-12

09/12/11

FDIC

SAT

Apr-12

09/12/11

Savers Coop Bank

Southbridge

yes

HS

Jan-12

11/22/10

FDIC

SAT

Mar-12

11/22/10

Savings Bank, The

Wakefield

yes

SAT

Aug-13

03/18/13

FDIC

SAT

Oct-13

03/18/13

S-Bank

Weymouth

yes

SAT

Jan-12

07/25/11

FDIC

SAT

Feb-12

07/25/11

Scituate FSB

Scituate

no

OCC

OUT

Dec-12

10/01/12

Seamen's Bank

Provincetown

yes

HS

Jul-12

12/20/11

FDIC

SAT

Jul-12

12/20/11

South Shore SB

Weymouth

yes

SAT

Oct-12

04/09/12

Fed

SAT

Aug-12

04/09/12

Southbridge SB

Southbridge

yes

HS

Dec-11

06/20/11

FDIC

SAT

Jan-12

06/20/11

Spencer SB

Spencer

yes

HS

Mar-11

10/18/10

FDIC

SAT

May-11

10/18/10

State Street B&T

Boston

yes

OUT

Oct-13

01/14/13

Fed

OUT

May-13

01/14/13

StonehamBank

Stoneham

yes

SAT

Jan-13

09/04/12

FDIC

SAT

Mar-13

09/04/12

Stoughton Coop Bank^^

Stoughton

yes

SAT

Oct-12

05/21/12

Fed

SAT

Dec-12

TD Bank

Wilmington DE

no

OCC

OUT

TrustCo Bank

Schenectedy NY

no

UniBank for Savings

Whitinsville

yes

United Bank

W. Springfield

no

Village Bank

Newton

yes

SAT

Jun-12

Wakefield Coop Bank

Wakefield

yes

SAT

Aug-09

Walpole Coop Bank

Walpole

yes

OUT

Washington SB

Lowell

yes

Watertown SB

Watertown

yes

Webster Bank, NA

Waterbury CT

no

Webster Five Cents SB

Webster

Wellesley Bank

yes

SAT

06/26/13 01/14/13

Feb-11

07/06/10

OUT Mar-12

09/28/10

Dec-12

05/21/12 12/31/11

OCC

SAT

FDIC

SAT

OCC

SAT

Jan-13

01/17/12

FDIC

SAT

Aug-12

01/17/12

06/09/09

FDIC

SAT

Sep-09

06/09/09

Mar-12

11/14/11

Fed

OUT

Mar-12

11/14/11

OUT

Jun-13

02/19/13

Fed

OUT

Jun-13

02/19/13

OUT

Oct-12

06/04/12

Fed

OUT

Oct-12

06/04/12

OCC

SAT Mar-12

yes

OUT

Jan-13

08/27/12

FDIC

OUT

Mar-13

Wellesley

yes

SAT

Aug-11

04/13/11

FDIC

SAT

Feb-09

Westfield Bank

Westfield

no

OCC

OUT

Weymouth Bank^^

Weymouth

yes

SAT

May-10

01/25/10

Fed

SAT

Jul-10

01/25/10

Winchester Coop Bank

Winchester

yes

SAT

Aug-11

03/14/11

FDIC

SAT

Oct-11

03/14/11

Winchester SB

Winchester

yes

SAT

Dec-11

07/11/11

FDIC

SAT

Feb-12

07/11/11

Winter Hill Bank

Somerville

no

OCC

OUT

Sep-13

07/15/13

Wrentham Coop Bank

Wrentham

yes

FDIC

SAT

Jan-14

07/08/13

SAT

SAT

Apr-12

Aug-11

08/22/11

05/02/11

[2010] 01/05/10 Apr-12

Sep-13

08/22/11 10/29/12

02/07/11 08/27/12 09/02/08 06/17/13

* indicates banks with potentially confusing recent name changes within the last four years: Adams Community Bank was, until February 2012, South Adams SB BayCoast Bank was, until January 2012, Citizens-Union SB Blue Hills Bank was, until November 2011, Hyde Park SB MountainOne Bank was, until July 2013, Hoosac Bank MutualOne Bank was, until July 2012, Framingham Cooperative Bank Sage Bank was, until June 2013, Lowell Co-op Bank Santander Bank was, until October 2013, Sovereign Bank Italic type indicates the 38 banks with branches both inside and outside of Massachusetts. See Table A-2 and its notes for more detailed info on all banks with branches both inside and outside of Mass. # (when following "yes" in "Mass Reg?" column -- that is, "yes#" ) indicates nine banks chartered by other states that have one or more branches in Mass. and are therefore subject to examinations and ratings under the Mass. CRA. ** Beal Bank USA's branch in Mass. formerly belonged to Beal Bank SSB. Rating is for Beal Bank SSB. ^ indicates five banks now regulated by the OCC whose most recent ratings is by the OTS. ^^ indicates 11 banks that now have the Fed as their federal regulator, but have CRA ratings from former regulators -from the OCC for Brookine Bk,First Ipswich Bk, and Mutual Bank; from the FDIC for the other 8. @ HarborOne Bank was HarborOne CU until July 2013. State rating shown was received when it was a credit union.

TABLE A-2 BANKS WITH BRANCHES BOTH INSIDE AND OUTSIDE OF MASSACHUSETTS (Data as of June 30, 2013)

Bank Name

Headquarters

Mass.

Branches Other Mass. %

Deposits ($ millions) Mass. Other Mass. %

A. Banks with Massachuse tts He adquarte rs Admirals Bank BayCoast Bank Berkshire Bank Boston Private B&T Bristol County SB Enterprise B&T First Trade Union Bank, FSB Lowell Five Cents SB Merrimac SB Milford Federal S&L Newburyport Five Cents SB OneUnited Bank Pentucket Bank Provident Bank Randolph SB United Bank Westfield Bank

Boston Fall River Pittsfield Boston Tauton Lowell Boston Lowell Merrimac Milford Newburyport Boston Haverhill Amesbury Randolph West Springfield Westfield

Total, 17 Banks

2 15 34 11 17 18 1 15 1 3 7 3 3 3 5 25 12

1 1 43 12 1 4 1 1 1 1 1 6 2 4 2 12 1

66.7% 93.8% 44.2% 47.8% 94.4% 81.8% 50.0% 93.8% 50.0% 75.0% 87.5% 33.3% 60.0% 42.9% 71.4% 67.6% 92.3%

339 737 2,071 3,011 1,036 1,440 458 781 41 263 426 29 429 285 290 1,352 783

218 40 1,777 1,617 58 140 25 7 24 41 0.4 319 115 185 40 600 83

60.9% 94.9% 53.8% 65.1% 94.7% 91.1% 94.8% 99.1% 63.1% 86.5% 99.9% 8.3% 78.9% 60.6% 87.9% 69.3% 90.4%

175

94

65.1%

13,771

5,289

72.2%

256 3 1 1 1 23 2 12 4 5 4 1 56 252 1 2 229 157 4 22

5,143 6 19 13 49 1,008 112 430 62 158 5 70 364 750 1 6 488 1,178 134 145

4.7% 33.3% 5.0% 7.1% 2.0% 2.2% 1.8% 2.7% 6.1% 3.1% 44.4% 1.4% 13.3% 25.1% 50.0% 25.0% 31.9% 11.8% 2.9% 13.2%

57,996 84 33.0 3,335 47 1,811 241 300 3,001 111 126 49 3,123 29,029 51 45 18,362 11,667 28 1,487

961,088 351 3,029 10,632 7,276 444,411 18,337 27,369 25,228 5,794 189 33,021 18,876 46,890 221 453 31,179 166,653 3,865 13,548

5.7% 19.3% 1.1% 23.9% 0.6% 0.4% 1.3% 1.1% 10.6% 1.9% 40.0% 0.1% 14.2% 38.2% 18.8% 9.0% 37.1% 6.5% 0.7% 9.9%

1,036

10,141

9.3%

130,926

1,818,410

6.7%

B. Banks with Non-Massachuse tts He adquarte rs Bank of America, NA Bank of New England Beal Bank, SSB BNY Mellon, NA Cathay Bank CitiBank, NA East West Bank First Niagara Bank, NA First Republic Bank NBT Bank, NA Northeast Community Bank Northern Trust Co People's United Bank RBS Citizens NA Salem Coop Bank Salisbury B&T Santander Bank TD Bank, NA TrustCo Bank Webster Bank, NA Total, 20 Banks

Charlotte NC Salem NH Plano, TX Pittsburgh PA Los Angeles CA Sioux Falls SD Pasadena CA Buffalo NY San Francisco CA

Norwich NY White Plains NY Chicago IL Bridgeport CT Providence RI Salem NH Lakeville CT Wilmington DE Wilmington DE Schenectedy NY Waterbury CT

Source: FDIC, Summary of Deposits data, as of June 30, 2013 (www.fdic.gov). Also: This table ignores trust or investment banks with only branches that have no or minimal deposits. It also excludes Bank of New York Mellon, a wholesale bank whose CRA assessment area does not include any part of Massachusetts. The three banks shown in italics were not on in this table last year. Admirals Bank moved its headquarters from Rhode Island to Boston during 2013.

TABLE A-3 CURRENT RATINGS OF MASSACHUSETTS STATE-CHARTERED CREDIT UNIONS, YEAR-END 2013 Credit Union Name

City/Town

Alden CU

Chicopee

Align CU

Lowell

Allcom CU

Worcester

Alpha CU

Rating ExamDate

Credit Union Name

City/Town

Lowell Firefighters CU

Lowell

SAT

02/01/10

Luso-American CU

Peabody

SAT

07/23/12

Lynn Muni Empls CU

Lynn

SAT

06/03/08

Lynn Police CU

Lynn

SAT

09/08/09

05/04/09

Lynn Teachers CU

Lynn

SAT

09/13/10

12/08/09

Malden City Empls CU

Malden

SAT

01/14/12

SAT

12/29/08

Mass Bay CU

Boston

SAT

11/22/10

Bridgewater

SAT

08/02/10

Mass Family CU

Lynn

HS

12/21/09

Brookline Municipal CU

Brookline

SAT

05/23/11

Members Plus CU

Boston

SAT

02/11/13

Brotherhood CU

Lynn

SAT

01/05/11

Metro CU

Chelsea

HS

11/19/12

Cabot Boston CU

Boston

SAT

10/01/08

New Bedford CU

New Bedford

SAT

06/09/08

Cambridge Portuguese CU

Cambridge

HS

12/08/08

Newton Municipal CU

Newton

SAT

04/22/08

Chicopee Muni Empls CU

Chicopee

SAT

01/29/13

Newton Teachers CU

Newton

SAT

11/14/12

City of Boston CU

Boston

SAT

11/27/12

One Twenty CU

Boston

SAT

01/11/01

Comm. Utils Empl's CU

Marion

SAT

10/05/07

Polish National CU

ChicopeeFalls

SAT

10/16/08

Community CU of Lynn

Lynn

HS

08/20/07

Premier Source CU

Springfield

SAT

06/04/12

Credit U of the Berkshires

Pittsfield

SAT

05/13/08

Pressers Union Local 12 CU

Boston

SAT

06/21/06

Crescent CU

Brockton

HS

06/03/13

Quincy CU

Quincy

SAT

05/05/09

Energy CU

Waltham

SAT

11/17/08

Revere Firefighters CU

Revere

SAT

10/24/12

Everett CU

Everett

SAT

03/14/11

River Works CU

Lynn

SAT

06/09/08

Fall River Muni CU

Fall River

SAT

01/12/09

Salem Italian Amer CU

Salem

SAT

05/21/13

First Choice CU

Lawrence

HS

04/27/09

Seaport CU

Salem

SAT

12/28/09

First Priority CU

Boston

SAT

02/08/10

Sharon CU

Sharon

SAT

02/11/13

Freedom CU

Springfield

SAT

02/07/12

Southbridge CU

Southbridge

HS

03/26/07

Gloucester Fire Dept CU

Gloucester

OUT

01/04/06

Southern Mass CU

Fairhaven

HS

11/27/12

Gloucester Muni CU

Gloucester

SAT

07/09/08

Springfield Street RR Empls CUSpringfield

SAT

09/26/06

Grafton Suburban CU

Grafton

SAT

10/14/08

St. Anne CU

New Bedford

HS

02/17/04

Greater Springfield CU

Springfield

SAT

04/15/09

St. Anne's CU

Fall River

Harvard U Empls CU

Cambridge

SAT

07/23/12

St. Jean's CU

Lynn

Haverhill Fire Dept CU

Haverhill

SAT

05/21/13

St. Mary's CU

Marlborough

Holyoke CU

Holyoke

HS

09/15/09

St. Vincent Hosp CU

Worcester

Holyoke Postal CU

Holyoke

SAT

07/15/08

STCU

Springfield

SAT

01/20/09

HTM CU

Haverhill

SAT

06/10/08

Tremont CU

Boston

SAT

05/25/05

Industrial CU

Boston

SAT

02/10/09

Waltham Muni Empls CU

Waltham

SAT

08/15/13

Jeanne D'Arc CU

Lowell

OUT

09/10/12

Watertown Municipal CU

Watertown

SAT

02/21/12

Landmark CU

North Adams

SAT

11/14/07

Worcester CU

Worcester

SAT

11/17/08

Lawrence Postal Empls CU

Lawrence

SAT

05/01/08

Worcester Fire Dept CU

Worcester

HS

04/15/08

Leominster CU

Leominster

SAT

02/06/12

Worcester Police CU

Worcester

SAT

01/28/13

Liberty Bay CU

Boston

SAT

02/05/07

Workers' CU

Fitchburg

OUT

09/12/11

SAT

10/31/07

HS

02/29/12

SAT

07/01/08

Boston

HS

04/14/08

Athol Credit Union

Athol

SAT

Billerica Muni Empls CU

Billerica

SAT

Boston Firefighters CU

Boston

Bridgewater CU

Rating ExamDate

SAT

09/25/12

HS

08/23/10

HS

08/23/10

SAT

03/20/13

Of the 78 current state-chartered credit unions, 60 have a current rating of SATisfactory. The three current OUTstanding ratings are indicated in bold. The fifteen current High Satisfactory (HS) ratings are indicated in italics.

TABLE A-4 PERFORMANCE RATINGS OF CURRENTLY LICENSED MORTGAGE LENDERS UNDER THE MORTGAGE LENDER COMMUNITY INVESTMENT REGULATION (CRA FOR MORTGAGE LENDERS), 2009-2013 Lender

Headquarters

Rating

List Date

Exam Date

2012 Rank Among LMLs^

American Interbanc Mortgage American Internet Mortgage

Irvine CA San Diego CA

NA* SAT

NA* Jul-10

11/26/10 08/31/09

65 43

Amerisave Mortage

Atlanta GA

NA*

NA*

01/27/10

17

Atlantic Home Lending

Canton MA

SAT

Jan-12

12/07/10

51

Broker Solutions Commonwealth Mortgage

Irvine CA Woburn MA

SAT SAT

Jun-12 Nov-13

06/02/11 04/22/13

85 24

Continental Homes Loan

Melville NY

SAT

Jun-12

03/02/12

73

Crescent Morttage

Atlanta GA

SAT

Apr-13

04/04/12

37

Embrace Home Loans Franklin American Mortgage

Newport RI Franklin TN

SAT SAT

May-10 Nov-10

02/02/10 06/09/10

41 16

Franklin First Financial Freedom Mortgage

Melville NY Mt. Laurel NJ

SAT SAT

Nov-11 May-10

04/12/11 12/11/09

83 36

Gateway Funding DMS GMH Mortgage Services

Horsham PA Newton Sq. PA

SAT SAT

Jan-11 Apr-13

12/11/09 09/20/12

62 BT

Homestead Funding iFreedom Direct

Albany NY Salt Lake City UT

SAT SAT

Jul-11 Jul-11

12/22/10 02/03/11

75 71

Leader Mortgage Maverick Funding

Arlington MA Parsipanny NJ

NI SAT

none Aug-13

08/03/10 01/02/13

14 52

Member Advantage Mortgage Members Mortgage

Ada MI Woburn MA

NI SAT

Jun-13 Nov-11

08/21/10 05/16/11

50 28

Merrimack Mortgage Mid-Island Mortgage

Manchester NH Westbury NY

SAT SAT

Jan-11 Oct-13

09/07/10 05/09/13

MLD Mortgage Monument Mortgage

Florham Park NJ Lexington MA

SAT SAT

Nov-11 Oct-09

03/24/11 04/21/09

12 53 NL NL

Mortgage Financial Mortgage Network

Tweksbury MA Danvers MA

SAT SAT

Apr-11 Apr-13

09/07/10 08/06/11

19 4

MSA Mortgage Nationstar Mortgage

Winthrop MA Lewisville TX

SAT SAT

Dec-09 Jan-14

06/30/09 08/14/12

9 27

NE Moves Mortgage NFM

Waltham MA Linthicum MD

SAT SAT

Jan-10 Nov-11

07/29/09 05/23/11

11 74

Plaza Home Mortgage Poli Mortgage Group

San Diego CA Norwood MA

NI NI

Sep-10 Oct-11

05/10/10 03/03/11

35 7

Primary Residential Mortgage Pulte Mortgage

Salt Lake City UT Englewood CA

SAT SAT

Nov-11 Aug-10

07/13/11 03/02/10

47 67

Radius Financial Group

Norwell MA

SAT

Nov-09

06/30/09

15

Regency Mortgage Reliant Mortgage

Manchester NH Beverly MA

SAT SAT

Dec-11 Feb-11

06/30/11 11/08/10

94 10

Ross Mortgage Shamrock Financial

Westborough MA E. Providence RI

SAT SAT

Oct-09 Nov-09

04/29/09 06/22/09

48 56

Sierra Pacific Mortgage Stearns Lending

Folsom CA Santa Ana CA

SAT SAT

Aug-10 Oct-12

02/15/10 12/06/11

20 18

HS

Sep-10

03/11/10

26

United Shore/United Wholesale Mort

Suntrust Mortgage

Richmond VA Troy MI

SAT

Sep-13

12/12/12

29

William Raveis Mortgage

Shelton CT

SAT

Sep-11

10/12/10

30

^ Lenders are ranked by total number of Massachusetts loans reported in 2012 HMDA data: 166 licensed lenders reported one or more loans, with exactly 100 of these reporting fifty or more loans. In this column, BT indicates that the lender's 2012 HMDA-reported loans were Below the Threshold of 50; NL indicates no loans reported in 2012 HMDA data. NA*: These exams resulted not in ratings but in Consent Orders that required these lenders to rectify "substantial noncompliance with applicable federal and state statutes, rules, and regulations," including incomplete loan records and inaccurate HMDA reporting that made an evaluation of lending performance impossible. Note: In addition to the 44 current lenders shown above, eight lenders that received ratings in previous years are no longer licensed as mortgage lenders in the state: Advanced, First Residential, Greenpark, MetroBoston, Mortgage Partners, Omega, Superior, and Union Capital. The licensing status of any mortgage lender can be found at www.nmlsconsumeraccess.org.