Arvest Bank, Fayetteville, AR, 01-11, 311845 Performance Evaluation

Transcription

PUBLIC DISCLOSURE
January 10, 2011
COMMUNITY REINVESTMENT ACT
PERFORMANCE EVALUATION
Arvest Bank
RSSD #311845
75 North East Street
Fayetteville, Arkansas 72701
Federal Reserve Bank of St. Louis
P.O. Box 442
St. Louis, Missouri 63166-0442
NOTE:
This document is an evaluation of this institution’s record of meeting
the credit needs of its entire community, including low- and moderateincome neighborhoods, consistent with safe and sound operation of the
institution. This evaluation is not, nor should it be construed as, an
assessment of the financial condition of the 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.
TABLE OF CONTENTS
I.
II.
III.
IV.
V.
VI.
Institution Rating
a.
Overall Rating......................................……………....……...
b.
Performance Test Ratings Table ...................................……
c.
Summary of Major Factors Supporting Rating ..............……
1
1
1
Institution
a.
Description of Institution……………………………………
b.
Scope of Examination……………………………………….
c.
Conclusions with Respect to Performance Tests……………
2
4
8
Fayetteville-Springdale-Rogers Multistate Metropolitan Statistical Area
(Arkansas and Missouri)
a.
Multistate Metropolitan Statistical Area Rating....................
b.
Scope of Examination............................................................
c.
Description of Institution‟s Operations .................................
d.
Conclusions with Respect to Performance Tests...................
18
19
19
24
Fort Smith Multistate Metropolitan Statistical Area (Arkansas and Oklahoma)
a.
b.
c.
Description of Institution‟s Operations .................................
d.
34
35
35
40
Kansas City Multistate Metropolitan Statistical Area (Kansas and Missouri)
a.
b.
c.
Description of Institution‟s Operations.................................
d.
50
51
51
56
Arkansas
a.
Summary
i.
State Rating………………………………………….
ii.
Scope of Examination……………………………….
iii.
Description of Institution‟s Operations……………...
iv.
Conclusions with Respect to Performance Tests……
64
65
65
66
b.
Little Rock-North Little Rock-Conway Metropolitan Statistical
Area (full-scope review)
i.
ii.
Table of Contents
73
77
c.
d.
VII.
VIII.
87
88
Nonmetropolitan Arkansas Statewide Area (full-scope review)
i.
ii.
90
95
Kansas
a.
Summary
i.
State Rating………………………………………….
ii.
iii.
iv.
105
106
106
111
Missouri
a.
Summary
i.
State Rating………………………………………….
ii.
iii.
iv.
119
120
120
121
b.
c.
d.
IX.
Hot Springs Metropolitan Statistical Area (limited-scope review)
i.
ii.
Joplin Metropolitan Statistical Area (limited-scope review)
i.
ii.
127
128
Springfield Metropolitan Statistical Area (limited-scope review)
i.
ii.
129
130
Nonmetropolitan Missouri Statewide Area (full-scope review)
i.
ii.
132
137
Oklahoma
a.
Summary
i.
State Rating………………………………………….
ii.
iii.
iv.
b.
Lawton Metropolitan Statistical Area (full-scope review)
i.
ii.
Table of Contents (continued)
145
146
146
147
154
158
c.
d.
e.
IX.
Tulsa Metropolitan Statistical Area (full-scope review)
i.
ii.
168
172
Oklahoma City Metropolitan Statistical Area (limited-scope
review)
i.
ii.
181
182
Nonmetropolitan Oklahoma Statewide Area (full-scope review)
i.
ii.
184
189
Appendix
a.
Scope of Examination Tables.................................................
b.
Summary of State and Multistate Metropolitan Statistical Area
Ratings………………………………………………………
c.
2009 Lending Performance Tables for Limited-Scope Review
Assessment Areas…………………………………………...
d.
2008 Lending Performance Tables (All Assessment Areas)
e.
Glossary………………………………………………..........
Table of Contents (continued)
198
200
201
213
252
Arvest Bank
Fayetteville, Arkansas
CRA Performance Evaluation
January 10, 2011
INSTITUTION’S CRA RATING
INSTITUTION'S CRA RATING: SATISFACTORY
The following table indicates the performance level of Arvest Bank with respect to the Lending,
Investment, and Service Tests.
Arvest Bank
PERFORMANCE TESTS
Performance Levels
Lending Test*
Investment Test
X
X
Service Test
Outstanding
High Satisfactory
Low Satisfactory
X
Needs to Improve
Substantial Noncompliance
*Note: The Lending Test is weighted more heavily than the investment and service tests when arriving at an overall
rating.
The major factors supporting the institution‟s rating include the following:
The bank‟s lending levels reflect good responsiveness to assessment area credit needs.
The bank makes a substantial majority of loans inside its designated assessment areas.
The overall geographic distribution of the loans reflects adequate penetration throughout the
bank‟s assessment areas.
The distribution of loans by borrower‟s income/revenue profile reflects excellent penetration
among customers of different income levels and businesses/farms of different sizes.
Overall, the bank makes a relatively high level of community development loans.
The bank makes a significant level of qualified community development investments and
grants.
Service delivery systems are reasonably accessible to all portions of the bank‟s assessment
areas, and changes in branch locations have not adversely affected the accessibility of
delivery systems, particularly to low- and moderate-income (LMI) geographies and/or LMI
individuals.
The bank provides an adequate level of qualified community development services.
1
Arvest Bank
January 10, 2011
INSTITUTION
DESCRIPTION OF INSTITUTION
Arvest Bank, headquartered in Fayetteville, Arkansas, is a wholly-owned subsidiary of the
Arvest Bank Group, Inc., of Bentonville, Arkansas, a one-bank holding company reporting total
assets of $11.6 billion as of December 31, 2010. Arvest Bank has several finance-related
affiliates, including the following subsidiaries: Arvest Mortgage Company, Arvest Asset
Management, Security BankCard Center, Superior Finance Company, Central Mortgage
Company, and Waco Title Company. In addition, the bank is affiliated with Arvest Trust
Company through common ownership.
The bank operates 239 branches (233 traditional bank offices and six drive-up only branches),
spread across Arkansas, Kansas, Missouri, and Oklahoma. The bank‟s main office is located in
Fayetteville, Arkansas, which is in the Fayetteville, Arkansas-Missouri metropolitan statistical
area (MSA) in northwest Arkansas. The bank has a significant presence in this and other parts of
Arkansas, as well as a significant presence in Oklahoma. Since the bank‟s previous CRA
evaluation, the bank closed five facilities and added or opened 23 branches, most notably
through a 2009 bank acquisition including six offices located in the Kansas City, MissouriKansas MSA. In light of this branch network expansion, the bank added one new CRA
assessment area (the Kansas City, Missouri-Kansas MSA Assessment Area) and expanded
previous nonMSA assessment areas in all four states. This includes eight additional counties in
Arkansas, seven additional counties in Missouri, 21 additional counties in Oklahoma, and three
additional counties in Kansas. The bank currently operates in 14 CRA assessment areas, as
detailed below.
Fayetteville, Arkansas-Missouri MSA
Fort Smith, Arkansas-Oklahoma MSA
Kansas City, Kansas-Missouri MSA
Little Rock, Arkansas MSA
Hot Springs, Arkansas MSA
NonMSA Arkansas
NonMSA Kansas
Joplin, Missouri MSA
Springfield, Missouri MSA
NonMSA Missouri
Lawton, Oklahoma MSA
Tulsa, Oklahoma MSA
Oklahoma City, Oklahoma MSA
NonMSA Oklahoma
2
Arvest Bank
January 10, 2011
For this review period, no legal impediments or financial constraints were identified that would
have hindered the bank from serving the credit needs of its customers, and the bank appeared
capable of meeting assessment area credit needs based on its available resources and financial
products. Arvest Bank reported total assets of $11.5 billion as of December 31, 2010, which
represents an increase in assets of 17.3 percent since the previous evaluation. Arvest Bank also
reported total loans of $7.4 billion (64.1 percent of total assets) and total deposits of about $9.5
billion. A distribution of the bank‟s lending portfolio, by both dollar amount and percentage, is
displayed in the following table.
Distribution of Total Loans
Amount in $000s
Percentage of
Total Loans
$
$
$
$
$
$
$
$
$
827,513
2,208,041
186,432
1,805,867
302,807
79,891
1,049,269
803,399
134,266
11.2%
29.8%
2.5%
24.4%
4.1%
1.1%
14.2%
10.9%
1.8%
$
7,397,485
100%
Credit Product Type
Construction and Development
Commercial Real Estate
Multifamily Residential
1-4 Family Residential
Farmland
Farm Loans
Commercial and Industrial
Loans to Individuals
Total Other Loans & Leases
GROSS LOANS & LEASES
Based on information presented in the previous table, the bank‟s primary lending focus continues
to include commercial real estate secured loans (29.8 percent) and residential real estate loans
(24.4 percent).1
The bank received a satisfactory rating at its previous CRA evaluation conducted as of
November 3, 2008.
1
The bank and its mortgage company affiliates also originate and subsequently sell a significant volume of loans
related to residential real estate; as these loans are typically sold on the secondary market shortly after origination,
this activity would not be captured in the data discussed here.
3
Arvest Bank
January 10, 2011
SCOPE OF EXAMINATION2
The bank‟s CRA performance was reviewed using the Federal Financial Institutions‟
Examination Council‟s (FFIEC) Interagency CRA Procedures for Large Institutions. The large
bank performance standards entail three performance tests, including the lending, investment,
and services tests. Bank performance under these tests is rated at the institution level, as well as
by state and multistate MSA. As previously noted, Arvest Bank has 14 assessment areas,
including three multistate MSAs and portions of four states; this includes the Kansas City,
Missouri-Kansas MSA Assessment Area, which was added in light of a 2009 bank acquisition.
The following table details branch distribution, as well as the scope of review procedures
performed by assessment area.
Number of
Facilities
State/Multistate MSA/Assessment Area
Multistate MSA
Fayetteville, Arkansas-Missouri MSA
Fort Smith, Arkansas-Oklahoma MSA
Kansas City, Kansas-Missouri MSA
52
17
10
Full-Scope Review
Full-Scope Review
Full-Scope Review
State of Arkansas
Little Rock, Arkansas MSA
24
Full-Scope Review
Hot Springs, Arkansas MSA
NonMSA Arkansas
3
21
Limited-Scope Review
Full-Scope Review
State of Kansas
NonMSA Kansas
1
State of Missouri
Joplin, Missouri MSA
Springfield, Missouri MSA
NonMSA Missouri
10
4
4
State of Oklahoma
Lawton, Oklahoma MSA
5
Tulsa, Oklahoma MSA
Oklahoma City, Oklahoma MSA
NonMSA Oklahoma
2
Review Type
29
27
32
Full-Scope Review
Full-Scope Review
Full-Scope Review
Full-Scope Review
Full-Scope Review
Information presented in this section (e.g., review period dates and loan sample details) pertains throughout the rest
of this evaluation unless specifically noted otherwise.
4
Arvest Bank
January 10, 2011
Based on the information displayed in the previous table, Arvest Bank‟s CRA performance was
rated under seven rating categories, in addition to the bank‟s overall institution rating. As part of
this evaluation, the bank received three multistate MSA ratings and four state ratings (as well as
individual Lending, Investment, and Service Test ratings under each rating category). The
bank‟s institution rating is a blend of these ratings, which are weighted based upon significance
to overall institution operations. In light of the bank‟s branch structure, loan and deposit activity,
and supervisory history, CRA performance in three rating categories received primary
consideration—Oklahoma, Fayetteville Arkansas-Missouri MSA, and Arkansas. Remaining
rating categories received secondary consideration (in order of priority)—Fort Smith ArkansasOklahoma MSA, Missouri, Kansas, and the Kansas City Missouri-Kansas MSA.
Lending Test
Arvest Bank‟s Lending Test performance was largely based upon 2008 and 2009 lending
activity, including home mortgage loans reported under the Home Mortgage Disclosure Act
(HMDA) and small business/farm loans reported under the CRA. While the Lending Test
analyses encompass lending activity from both 2008 and 2009, the body of this evaluation
primarily details bank performance based upon 2009 lending activity, noting significant
divergences in performance between the two years, as applicable (see Appendix D for detailed
performance figures based on 2008 lending activity). Also, the review period for community
development lending activity spanned from 2008 (including community development lending
activity not considered as part of the previous CRA evaluation) to the date of this evaluation.
In addition to the direct lending activity noted above, certain 2008 and 2009 affiliate lending
activity was also included in the scope of this evaluation, at the bank‟s option. This affiliate
lending activity is attributable to two of Arvest Bank‟s subsidiaries, Arvest Mortgage Company,
Fayetteville, Arkansas, and Security BankCard Center, Norman, Oklahoma. Arvest Mortgage
Company originates dwelling-related loans that are included in the bank‟s HMDA loan category,
and Security BankCard Center originates business loans via credit card extensions, which are
included in the bank‟s small business/small farm loan categories.
5
Arvest Bank
January 10, 2011
Under the Lending Test, the bank‟s performance is evaluated under the following criteria, as
applicable.
Level of Lending Activity
Assessment Areas Concentration3
Geographic Distribution of Loans
Distribution of Loans by Borrower‟s Income/Revenue Profile
Community Development Lending Activity
Product Innovation4
Under the Lending Test criteria noted above, analyses often entail comparisons of bank
performance to assessment area demographics and the performance of other lenders (based upon
HMDA and CRA aggregate lending data). Unless otherwise noted, assessment area
demographics are based upon 2000 U.S. Census Data. Certain business and farm
geodemographics are based upon Dun & Bradstreet data, as applicable to the year of bank
lending activity being considered.
Investment Test
The review of community development investments and grants includes qualified activity from
the date of the previous CRA evaluation to the date of the current evaluation. In addition,
investments made prior to the date of the previous CRA evaluation but still outstanding as of this
review date were also considered. Community development investments can include various
investment vehicles, such as bonds, individual equities, mutual fund shares, monetary
donations/grants, etc. Qualified investments and grants were evaluated to determine the bank‟s
overall level of activity, use of innovative and/or complex investments,5 as well as
responsiveness to assessment area credit and community development needs.
Service Test
The review period for retail and community development services includes activity from the date
of the previous CRA evaluation to the date of the current evaluation. The Service Test considers
the distribution and accessibility of bank branches/alternative delivery systems, changes in
branch locations, the reasonableness of business hours/retail services, and community
development services.
3
This review is performed at the institution level only, and it does not include affiliate lending activity.
Unlike other large bank CRA performance criteria, a lack of innovative and/or flexible lending practices does not
necessarily impact the bank‟s performance negatively, as these activities are largely used to augment
consideration given to an institution‟s performance under the quantitative criteria, resulting in a higher
performance rating.
5
Unlike other large bank CRA performance criteria, a lack of innovative and/or complex investments does not
necessarily impact the bank‟s performance negatively, as these activities are largely used to augment
consideration given to an institution‟s performance under the quantitative criteria, resulting in a higher
performance rating.
4
6
Arvest Bank
January 10, 2011
Other
To augment this evaluation, ten interviews (community contacts) were conducted with
community members of the bank‟s various assessment areas. In addition to the new community
contacts completed as a part of this evaluation, numerous previously completed community
contacts were also referenced when available and pertinent to the subject assessment area being
reviewed. The following table displays the number of community contacts utilized as part of
each full-scope assessment area review.
New
Community
Contacts
Other
Community
Contacts
TOTAL
Fayetteville, AR-MO MSA
1
4
5
Fort Smith, AR-OK MSA
1
3
4
Kansas City, KS-MO MSA
0
7
7
Little Rock, AR MSA
0
2
2
NonMSA AR
1
3
4
NonMSA KS
2
0
2
NonMSA MO
2
0
2
Lawton, OK MSA
2
0
2
Tulsa, OK MSA
0
3
3
NonMSA OK
1
3
4
10
25
35
Assessment Area
TOTAL
These community contacts were utilized in order to ascertain specific credit needs/opportunities
and local market conditions within the bank‟s assessment areas. Information from these
interviews also assisted in evaluating the bank‟s responsiveness to identified community credit
needs and community development opportunities.6
6
Key details from these community contact interviews are included in the Description of Institution’s Operations
sections, as applicable to the assessment areas in which the community contacts were made.
7
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS
LENDING TEST
Arvest Bank‟s performance under the Lending Test is rated high satisfactory. Arvest Bank‟s
overall lending levels reflect good responsiveness to the credit needs of its combined assessment
areas. An analysis of the bank‟s lending activity revealed that a substantial majority of loans are
made inside the bank‟s assessment areas. Further, the geographic distribution of loans reflects
adequate penetration throughout the assessment areas, including LMI geographies. An analysis
of the loan distribution by borrower income reflects excellent penetration among customers of
different income levels and businesses and farms of different revenue sizes. In addition, Arvest
Bank made a relatively high level of community development loans. Finally, the bank makes
limited use of innovative and flexible lending practices in order to better serve the credit needs of
its assessment areas. The following table reflects the corresponding Lending Test ratings for the
multistate MSAs and states applicable to the bank‟s combined assessment areas.
State / Multistate MSA
Lending Test Rating
Fayetteville AR-MO MSA
High Satisfactory
Fort Smith AR-OK MSA
Low Satisfactory
Kansas City KS-MO MSA
High Satisfactory
Arkansas
High Satisfactory
Kansas
High Satisfactory
Missouri
High Satisfactory
Oklahoma
High Satisfactory
OVERALL
HIGH SATISFACTORY
8
Arvest Bank
January 10, 2011
Lending Activity
Overall the bank‟s lending levels reflect good responsiveness to credit needs in the bank‟s
combined assessment areas. Lending activity based on the product lines reviewed during this
evaluation is detailed in following table.7
Summary of Lending Activity
Loan Type
%
$(000s)
%
Home Improvement
6,449
11.1%
$252,122
4.4%
Home Purchase
9,262
16.0%
$1,167,269
20.3%
93
0.2%
$111,489
1.9%
18,006
31.0%
$2,111,433
36.6%
Total HMDA related
33,810
58.3%
$3,642,313
63.2%
Small Business
19,091
32.9%
$1,882,923
32.7%
5,100
8.8%
$238,420
4.1%
58,001
100%
$5,763,656
100%
Multi-Family Housing
Refinancing
Small Farm
TOTAL LOANS
7
#
This table includes both bank-originated loans and affiliate-originated loans. However, only the affiliate-lending
activity made inside the bank‟s combined assessment areas is included here, while all bank activity is included
(both to borrowers inside and outside of the bank‟s assessment areas).
9
Arvest Bank
January 10, 2011
Assessment Areas Concentration
For the loan activity reviewed as part of this evaluation, the following table displays the number
and dollar volume of loans inside and outside the bank‟s assessment areas.8
Lending Inside and Outside of Assessment Area ($000s)
Inside
Outside
Loan Type
TOTAL
Assessment Area
Assessment Area
14,039
145
14,184
HMDA
99.0%
1.0%
100%
$ 823,539
$ 37,620
$ 861,159
95.6%
4.4%
100%
283
16,162
98.2%
1.8%
100%
$ 1,786,797
$ 53,559
$ 1,840,356
97.1%
2.9%
100%
5,063
36
5,099
99.3%
0.7%
100%
$ 234,922
$ 3,488
$ 238,410
98.5%
1.5%
100%
34,981
464
35,445
98.7%
1.3%
100%
$ 2,845,258
$ 94,667
$ 2,939,925
96.8%
3.2%
100%
15,879
Small Business
Small Farm
TOTAL
By number of total loans reviewed, 98.7 percent were made to borrowers within the bank‟s
assessment area. Further, data in the previous table demonstrate that a substantial majority of
loans (by both number and dollar amount of loans) are extended to borrowers residing inside the
bank‟s assessment areas for all three loan categories.
8
Loan activity displayed in this table does not include affiliate lending activity.
10
Arvest Bank
January 10, 2011
Geographic and Borrower Distribution
As is displayed in the following table, the bank‟s overall geographic distribution of loans reflects
adequate penetration throughout the bank‟s assessment areas in the various states/multistate
MSAs.
Adequate
Good
Good
Arkansas
Adequate
Kansas
Adequate
Missouri
Adequate
Oklahoma
Adequate
OVERALL
ADEQUATE
Overall, performance by borrower‟s income/revenue profile is excellent, as is displayed in the
following table.
Loan Distribution by Borrower’s Profile
Excellent
Excellent
Good
Arkansas
Excellent
Kansas
Excellent
Missouri
Excellent
Oklahoma
Good
OVERALL
EXCELLENT
11
Arvest Bank
January 10, 2011
Community Development Lending Activities
Overall, Arvest Bank maintains a relatively high level of community development loans.
Community Development Lending
Leader
Few, if any
Relatively High Level
Arkansas
Kansas
Few, if any
Missouri
Low level
Oklahoma
OVERALL
RELATIVIELY HIGH LEVEL
As displayed in the previous table, the bank‟s performance varied significantly by state and
multistate MSA. However, with the most weight being placed on the Fayetteville ArkansasMissouri MO MSA, the state of Oklahoma, and the state of Arkansas, Arvest Bank‟s overall
community development lending performance reflects a relatively high level of community
development loans.
The bank originated or renewed 45 community development loans and letters-of-credit within
the combined assessment areas totaling $138.9 million. The community development loans were
for a variety of purposes, including affordable housing (22), economic development (1),
revitalization/stabilization of LMI geographies (14), and community development services (8).
Included in this activity are multiple loans for projects associated with the New Markets Tax
Credit Program (NMTC), which is considered an innovative program that provides equity capital
to further commercial economic development activities in underserved geographies. To qualify
for NMTCs, entities must be a domestic corporation that has a mission of serving low-income
communities or individuals, maintains accountability to the residents of low-income
communities, and must be certified by the United States Department of the Treasury‟s
Community Development Financial Institutions (CDFI) Fund. This CDFI certification facilitates
the credit flow to businesses serving the needs of LMI individuals and ensures these businesses
continue to benefit LMI areas.
12
Arvest Bank
January 10, 2011
INVESTMENT TEST
Overall, Arvest Bank is rated high satisfactory for the Investment Test. The bank made a
significant level of qualified community development investments and grants and is occasionally
in a leadership position. Arvest Bank makes occasional use of complex investments to support
community development initiatives. The following is a breakdown of the Investment Test rating
for all rated areas.
Investment Test Rating
Outstanding
Low Satisfactory
Low Satisfactory
Arkansas
High Satisfactory
Kansas
Needs to Improve
Missouri
Low Satisfactory
Oklahoma
High Satisfactory
OVERALL
HIGH SATISFACTORY
As displayed in the previous table, the bank‟s Investment Test performance was outstanding in
its most significant rated area, the Fayetteville Arkansas-Missouri MSA. While the bank was
rated needs to improve in the state of Kansas, performance in this rated area played a small role
related to overall rating conclusions, as bank operations in Kansas have the least significance
compared to other state/multistate MSAs.
During the evaluation period, the bank made or participated in CRA-qualified investments for a
total investment balance of $41.7 million. This represents a decrease compared to the previous
examination total of $52.3 million. The majority of the bank‟s investments consist of purchased
portfolios of mortgage-backed securities (MBS). These MBS are secured by affordable housing
loans made to LMI individuals. The bank purchased $9.9 million of qualified MBS during this
review period, benefiting and attributable to eight assessment areas. Further, as of this evaluation
date, the bank maintained $16.0 million of qualified MBS purchased prior to this evaluation,
which are secured by loans throughout all of the bank‟s 14 assessment areas. Consequently, the
estimated community development investment benefit used here for evaluation purposes was
divided among the assessment areas based upon the bank‟s deposit market share by assessment
area.
Another noteworthy investment the bank makes is in Low Income Housing Credits and NMTC.
The bank has invested $15.8 million in these tax credits across three assessment areas. Further,
the bank made an excellent level of community development grants during this evaluation
period. The bank made 983 grants totaling over $2.1 million, reflecting an increase of $1.0
million in grant monies from the previous evaluation.
13
Arvest Bank
January 10, 2011
SERVICE TEST
Overall, Arvest Bank‟s performance is rated low satisfactory under the Service Test. The bank‟s
delivery systems are reasonably accessible to all geographies and individuals of different income
levels throughout the combined assessment areas. In addition, the bank‟s record of opening and
closing branches has not adversely affected the accessibility of its delivery systems, particularly
to LMI geographies and/or LMI individuals. Further, services do not vary in a way that
inconveniences the needs of its assessment area, particularly to LMI geographies and/or LMI
individuals. Lastly, Arvest Bank provides an adequate level of community development services
within the combined assessment areas. The following table reflects the bank‟s Service Test
ratings for all rated areas.
Service Test Rating
Low Satisfactory
High Satisfactory
Low Satisfactory
Arkansas
Low Satisfactory
Kansas
Low Satisfactory
Missouri
Low Satisfactory
Oklahoma
Low Satisfactory
OVERALL
LOW SATISFACTORY
As displayed in the previous table, the bank‟s Service Test performance was low satisfactory in
six of seven rated areas; the exception being the Fort Smith Arkansas-Oklahoma MSA, which
received a higher rating primarily due to the relatively higher level of community development
services attributable to this rating area.
14
Arvest Bank
January 10, 2011
Accessibility of Delivery Systems
Overall, the bank‟s delivery systems are reasonably accessible to the geographies and individuals
of different income levels in the bank‟s assessment areas.
Accessible
Readily Accessible
Reasonably Accessible
Arkansas
Kansas
Missouri
Oklahoma
Accessible
OVERALL
REASONABLY ACCESSIBLE
In addition to the standard retail services and community development services evaluated at the
state/multistate MSA and assessment area levels, the bank also maintains an Internet website
where, among other standard online banking features, customers can apply for a loan, open a
deposit account, and pay bills. In addition, the bank operates a 24-hour telephone banking line
where customers can obtain deposit and loan account information and transfer funds between
accounts.
15
Arvest Bank
January 10, 2011
Changes in Branch Locations
As displayed in the following table, the bank‟s record of opening and closing bank facilities
throughout its various assessment areas has not adversely affected the accessibility of its delivery
systems, particularly to LMI geographies and/or LMI individuals.
Generally Not Adversely Affected
Not Adversely Affected
Arkansas
Kansas
Missouri
Oklahoma
OVERALL
NOT ADVERSELY AFFECTED
Community Development Services
Overall, the bank provides an adequate level of community development services throughout its
various assessment areas, as displayed in the following table.
Adequate Level
Few, If Any
Arkansas
Limited Level
Kansas
Few, If Any
Missouri
Few, If Any
Oklahoma
Adequate Level
OVERALL
ADEQUATE LEVEL
While the bank‟s level of community development services is below satisfactory performance
standards in three rated areas (Kansas City Kansas-Missouri MSA, Kansas, and Missouri), the
bank‟s community development service performance was adequate or better in most rated areas,
including the top three primary rating areas.
16
Arvest Bank
January 10, 2011
FAIR LENDING OR OTHER ILLEGAL CREDIT PRACTICES REVIEW
Based upon past supervisory history and findings from the Consumer Affairs examination
(including a fair lending analysis performed under Regulation B - Equal Credit Opportunity and
the Fair Housing Act (FHA) requirements) conducted concurrently with this CRA evaluation, no
evidence of discriminatory or other illegal credit practices inconsistent with helping to meet
community credit needs was identified.
17
Arvest Bank
January 10, 2011
FAYETTEVILLE-SPRINGDALE-ROGERS
MULTISTATE MSA9
CRA RATING FOR FAYETTEVILLE ARKANSAS-MISSOURI MSA: SATISFACTORY
The Lending Test is rated:
High Satisfactory
The Investment Test is rated:
Outstanding
The Service Test is rated:
Low Satisfactory
Major factors supporting the institution‟s Fayetteville Arkansas-Missouri MSA (Fayetteville
MSA) rating include the following:
Arvest Bank‟s lending levels reflect good responsiveness to the credit needs in the
Fayetteville MSA.
The bank‟s overall geographic distribution of loans reflects adequate penetration throughout
the Fayetteville MSA.
among borrowers of different income levels and businesses/farms of different sizes.
The bank is a leader in making community development loans within the Fayetteville MSA.
The bank makes an excellent level of qualified community development investments and
grants within the Fayetteville MSA.
Service delivery systems are accessible to geographies and individuals of different income
levels in the Fayetteville MSA; further, changes in branch locations have generally not
adversely affected the accessibility of delivery systems, particularly to LMI geographies
and/or LMI individuals.
Arvest Bank personnel provides an adequate level of community development services in the
Fayetteville MSA.
9
This rating reflects performance within the multistate MSA. The Arkansas and Missouri statewide evaluations are
adjusted and do not reflect performance in the parts of those states contained within the Fayetteville MSA.
18
Arvest Bank
January 10, 2011
SCOPE OF EXAMINATION
Arvest Bank has one assessment area in the Fayetteville MSA, which includes the entire
multistate MSA. The bank‟s performance within the Fayetteville MSA was reviewed using fullscope examination procedures, and scoping considerations applicable to the review of this
assessment area are consistent with the overall CRA examination scope as presented in the
Institution, Scope of Examination section. Also, this evaluation included information obtained
through five community contact interviews completed in the Fayetteville MSA, including one
completed as part of this evaluation. The community contact completed as part of this review
took place with a director of planning and community development.10
DESCRIPTION OF INSTITUTION’S OPERATIONS IN FAYETTEVILLE MSA
Bank Structure
Arvest Bank operates 50 of its 233 full-service branches (21.5 percent) and two drive-up
facilitates within this assessment area. Of the combined facilities, none are located in lowincome census tracts (however, the bank does maintain multiple facilities within close proximity
of a low-income geography), seven are in moderate-income census tracts, 37 are in middleincome census tracts, and eight are located in upper-income census tracts. During this review
period, the bank did not open any new offices and closed three facilities in this assessment area
(the bank closed one full-service branch and two drive-up facilities). Based on this branch
network and other service delivery systems, the bank is well positioned to deliver financial
services to substantially all of the Fayetteville MSA Assessment Area.
This assessment area is a competitive banking market, with a total of 37 Federal Deposit
Insurance Corporation (FDIC) insured institutions operating within the MSA, based on the FDIC
Deposit Market Share Report as of June 30, 2010. Of those 37 financial institutions, Arvest
Bank held the largest amount of deposit dollars by far, with a deposit market share of 41.7
percent (the next closest market share percentage was 6.5 percent). The deposits held at
branches throughout the Fayetteville MSA represent 33.7 percent of all Arvest Bank deposits.
10
Key details from these community contact interviews are included in the next section, Description of Institution’s
Operations.
19
Arvest Bank
January 10, 2011
General Demographics
The Fayetteville MSA is a four-county multistate MSA including three counties in Arkansas and
one county in Missouri. Specifically, the Arkansas portions of the multistate MSA include
Benton, Madison, and Washington counties. The Missouri portion of the multistate MSA
consists of McDonald County. The multistate MSA is located in the northwest corner of
Arkansas and the southwest corner of Missouri.
Based on 2000 census data, the assessment area had a total population of 347,045. The majority
of the population lives in Washington County (157,715) and Benton County (153,406). There
are much smaller populations in McDonald County (21,681) and Madison County (14,243).
According to U.S. Census Bureau estimates as of July 2009, the population in the Fayetteville
MSA has grown significantly. The total MSA population in 2009 was estimated at 464,623.
This marks a total MSA population increase of 33.9 percent since the 2000 census.
As the demographics of this assessment area cover a wide metropolitan area, and the population
is diverse, credit needs in the area are also varied, including a standard blend of consumer and
business/farm credit products. Other particular credit needs in the assessment area (as noted
primarily during community contact interviews) include flexible residential real estate loan
programs and commercial operating lines-of-credit. Further, as the Fayetteville MSA is an
environment with significant need, coupled with an ample source of community development
intermediaries (such as nonprofit agencies, higher education institutions, and government
assistance entities), there is a high level of community development opportunity available for
financial institution participation.
Income and Wealth Demographics
The multistate MSA consists of 68 geographies. Based on the 2000 census, the median family
income for the Fayetteville MSA was $42,578, which was greater than the state of Arkansas
($38,663) but less than the state of Missouri ($46,044). As of 2009, the U.S. Department of
Housing and Urban Development (HUD) estimated median family income for the Fayetteville
MSA was $56,000, revealing that the assessment area has become significantly wealthier since
the 2000 census. The following table summarizes the distribution of geographies by income
level and the family population of those census tracts within the assessment area.
20
Arvest Bank
January 10, 2011
Assessment Area Demographics by Geography Income Level
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
2
11
46
9
0
68
16.2%
67.6%
13.2%
11,427
66,496
14,553
12.2%
71.2%
15.6%
2.9%
944
1.0%
0.0%
0
0.0%
100%
93,420
100%
The following table displays the distribution of assessment area families by income level, as well
as family population income characteristics for the states of Arkansas and Missouri.
Family Population by Income Level
Dataset
Assessment Area
Arkansas
Missouri
Low-
Moderate-
Middle-
Upper-
TOTAL
17,270
17,491
22,458
36,201
93,420
18.5%
18.7%
24.0%
38.8%
100%
148,233
131,570
163,567
292,693
736,063
20.1%
17.9%
22.2%
39.8%
100%
282,730
278,477
345,089
580,250
1,486,546
19.0%
18.7%
23.2%
39.0%
100%
Housing Demographics
While income levels in the Fayetteville MSA Assessment Area are relatively high, housing costs
in the assessment area still appear less affordable than state comparisons, due largely to higher
real estate values in the Fayetteville MSA. The assessment area housing affordability ratio was
40.0 percent as of the 2000 census, which is significantly below the housing affordability ratio
for of the state of Arkansas (47.0 percent) and slightly below the state of Missouri (43.0 percent).
Of the four MSA counties, housing is most affordable in McDonald County (46.0 percent),
followed by Benton County, Madison County, and Washington County (43.0, 39.0, and 39.0
percent, respectively). The median housing value in the assessment area is $88,400, which is
much higher than the state of Arkansas ($67,400) and slightly more than the state of Missouri
($86,900). Median gross rent in the Fayetteville MSA is also higher ($495) than both the state of
Arkansas ($453) and the state of Missouri ($484).
21
Arvest Bank
January 10, 2011
Industry and Employment Demographics
According to 2009 Dun & Bradstreet data, there were 19,458 business entities and 532
agricultural entities operating within the Fayetteville MSA. The area is the home to one of the
world‟s largest retail stores, a large meat and poultry producer, and a major North American
transportation company. The following table depicts employment levels by industry, comparing
the Fayetteville MSA economy to the state of Arkansas and the state of Missouri using the
“Location Quotient” measure.11
Fayetteville MSA - Employment by Industry
Industry
Natural Resources and Mining
Construction
Manufacturing
Trade, Transportation, and Utilities
Information
Financial Activities
Professional and Business Services
Education and Health Services
Leisure and Hospitality
Other Services
TOTAL
1,543
7,948
29,286
42,061
2,073
7,454
32,163
20,136
18,329
3,680
% of
Total
0.9%
4.8%
17.8%
25.5%
1.3%
4.5%
19.5%
12.2%
11.1%
2.2%
164,673
100%
Employment
LQ Arkansas
0.42
0.87
1.01
1.02
0.72
0.86
1.61
0.71
1.04
0.84
LQ Missouri
1.36
0.88
1.51
1.08
0.44
0.63
1.34
0.71
0.89
0.58
N/A
As displayed in the previous table, the largest industries in the Fayetteville MSA are trade,
transportation, and utilities; professional and business services; and manufacturing. The
assessment area industry mix is similar to the state of Arkansas, with noted exceptions being a
greater reliance on professional and business services and less reliance on natural resources and
mining. The industry mix varies significantly from the state of Missouri, most notably with a
greater reliance on manufacturing and less reliance on information-related industries.
The recent annual average unemployment rates for the Fayetteville MSA (4.0 percent in 2008
and 5.9 percent in 2009) were much lower than rates for both the state of Arkansas (5.3 percent
in 2008 and 7.4 percent in 2009) and the state of Missouri (6.1 percent in 2008 and 9.3 percent in
2009).12 Similar to the state of Arkansas and the state of Missouri, unemployment in the
Fayetteville MSA generally rose in 2010 and was projected to be at 6.8 percent in January
2011—a figure still lower than preliminary estimates for the state of Arkansas (8.7 percent) and
the state of Missouri (10.2 percent).
11
12
Source: 2009 Bureau of Labor Statistics, U.S. Department of Labor
Source: Bureau of Labor Statistics, U.S. Department of Labor (not seasonally adjusted)
22
Arvest Bank
January 10, 2011
Community Contact Information
Community contacts indicated that local banks continue to face financial distress as a result of
the downturn in the economy. In response to issues related to poor performing loans, banks are
focusing on low-risk borrowers. Due to this credit tightening, it was noted that finding funding
for very low-income individuals and start-up businesses has been difficult. Community contacts
stressed that the major credit needs in the area are residential real estate (FHA, conventional, and
rural housing development) and commercial operating lines-of-credit.
According to community contacts, Community Development Block Grant funds have been vital
in the area. Under this program, grant dollars provide housing and rehabilitation assistance
(loans for housing, emergency services, etc.) for LMI individuals. It was noted that financial
institution participation in programs such as this is adequate. However, areas requiring more
assistance include downtown revitalization, financing for small business development, and
coordinating with landlords to get rental properties up to standards of healthy and adequate living
conditions.
The contacts noted that the economy in the northwest Arkansas area is beginning to stabilize.
After the housing boom and subsequent foreclosures, vacancy rates increased in both the
residential and commercial sectors. Recent data indicate that home sales are beginning to rise, as
is consumer spending. Current unemployment levels are still above the pre-recession level;
however, there are signs of employment stabilization, as major employers in the area are hiring
back individuals who were previously laid-off.
23
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN FAYETTEVILLE
MSA
LENDING TEST
Arvest Bank‟s Lending Test performance in the Fayetteville MSA is rated high satisfactory.
Lending levels reflect good responsiveness to assessment area credit needs. The geographic
distribution of loans reflects adequate penetration throughout the assessment area. The loan
distribution by borrower‟s income/revenue profile reflects excellent penetration among
customers of different income levels and businesses/farms of different sizes. In addition, Arvest
Bank is a leader in making community development loans in this assessment area.
Lending Activity
The bank‟s lending levels within the Fayetteville MSA reflect good responsiveness to assessment
area credit needs based upon the lending activity analyzed under the Lending Test. This lending
activity is displayed by loan type in the following table.
Loan Type
$(000s)
%
17.5%
$97,203
9.6%
351
3.0%
$33,685
3.3%
25
0.2%
$26,633
2.6%
3,175
26.7%
$185,436
18.2%
Total HMDA related
5,633
47.4%
$342,957
33.7%
Small Business
4,769
40.2%
$599,836
59.0%
Small Farm
1,470
12.4%
$73,546
7.2%
11,872
100%
$1,016,339
100%
Home Improvement
Home Purchase
Refinancing
TOTAL LOANS
#
%
2,082
24
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Fayetteville MSA section, this
assessment area includes two low-income and 11 moderate-income census tracts, representing
19.1 percent of all assessment area census tracts. Overall, based on lending activity from all
three loan categories reviewed, the bank‟s geographic distribution of loans reflects adequate
penetration throughout this assessment area, including the 13 LMI census tracts. The following
table displays the geographic distribution of HMDA loans in comparison to owner-occupied
housing demographics for the assessment area.
Distribution of Loans Inside Assessment Area by Income Level of Geography
Dataset
Home Purchase
Refinance
Home
Improvement
Geography Income Level
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
6
63
1,297
347
0
3.7%
75.7%
20.3%
194
3,390
1,084
4.1%
72.5%
23.2%
26
471
133
4.1%
74.8%
21.1%
7
7
7
4.5%
31.8%
31.8%
31.8%
16
290
5,165
1,571
0.2%
4.1%
73.3%
22.3%
0.0%
100%
0.2%
11.7%
71.9%
16.2%
0.0%
100%
0.4%
9
0.2%
0
0.0%
1
0.0%
0
0.0%
0
0.0%
0
1,713
100%
4,677
100%
630
100%
22
Multi-Family
TOTAL
LOANS
Owner Occupied
Housing
0.0%
0
100%
7,042
The bank‟s HMDA lending in low-income geographies (0.2 percent) is adequate, as this
performance matches the owner-occupied housing percentage and is also in line with the 2009
HMDA aggregate lending level in low-income census tracts (0.3 percent). Similarly, bank
lending in moderate-income census tracts is also adequate. While the bank‟s lending in
moderate-income tracts (4.1 percent) is below the owner-occupied percentage (11.7 percent), it is
similar to the 2009 aggregate lending level in moderate-income census tracts (4.7 percent).
Consequently, the bank‟s overall geographic distribution of HMDA loans reflects adequate
penetration throughout this assessment area.
25
Arvest Bank
January 10, 2011
Second, the bank‟s geographic distribution of small business loans was reviewed, which is
displayed in the following table in comparison to the location of businesses throughout the
bank‟s assessment area.
Dataset
Small Business
Loans
Business
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
11
299
1,694
487
0
2,491
0.4%
12.0%
68.0%
19.6%
0.0%
100%
0.8%
15.0%
66.0%
18.2%
0.0%
100%
While below comparison data levels, the geographic distribution of the bank‟s small business
loans reflects adequate penetration throughout the assessment area, including LMI geographies.
The bank‟s performance in low-income tracts (0.4 percent) is below, but within adequate range
of the estimated percentage of businesses located in low-income census tracts (0.8 percent) and
the 2009 CRA aggregate lending level in low-income census tracts (0.7 percent). Similarly, the
bank‟s performance in moderate-income tracts (12.0 percent) is just below the estimated
percentage of businesses located in moderate-income census tracts (15.0 percent) and the CRA
aggregate lending level in moderate-income census tracts (14.1 percent). Therefore, the bank‟s
overall geographic distribution of small business loans is adequate.
26
Arvest Bank
January 10, 2011
Finally, the geographic distribution of the bank‟s small farm loans is displayed in the following
table in comparison to the location of farms throughout the assessment area.
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
120
569
18
0
707
0.0%
17.0%
80.5%
2.5%
0.0%
100%
0.0%
20.9%
72.7%
6.4%
0.0%
100%
According to Dun & Bradstreet estimates, 20.9 percent of farms in the assessment area reported
being located in moderate-income tracts (estimates indicate there are no farm lending
opportunities in low-income census tracts). While the bank‟s percentage of the small farm loans
in moderate-income census tracts, 17.0 percent, is slightly below the estimated percentage of
farms in moderate-income census tracts, this performance is good compared to the 2009 CRA
aggregate lending level in moderate-income census tracts, 15.6 percent. Therefore, the bank‟s
geographic distribution of small farm loans is good.
27
Arvest Bank
January 10, 2011
Overall, the bank‟s loan distribution by borrower‟s profile is excellent, based on performance
from all three loan categories reviewed. The following table shows the distribution of HMDA
loans by borrower income level in comparison to family population income characteristics.
Distribution of Loans Inside Assessment Area by Income Level of Borrower
Dataset
Home Purchase
Refinance
Home
Improvement
Borrower Income Level
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
191
416
490
602
14
1,713
11.2%
24.3%
28.6%
35.1%
0.8%
100%
294
651
964
2,717
51
4,677
6.3%
13.9%
20.6%
58.1%
1.1%
100%
80
135
344
24
12.7%
21.4%
54.6%
3.8%
0
0
0
47
7.5%
0
630
100%
22
22
100.0%
100%
Multi-Family
0.0%
TOTAL
LOANS
Families
0.0%
0.0%
0.0%
532
1,147
1,589
3,663
111
7,042
7.6%
16.3%
22.6%
52.0%
1.6%
100%
18.5%
18.7%
24.0%
38.8%
0.0%
100%
Based on the above table, the bank‟s level of lending to low-income borrowers (7.6 percent) is
lower than the low-income family population (18.5 percent). However, the bank‟s level of
lending is higher than the aggregate lending level to low-income borrowers (7.2 percent),
reflecting good bank performance. Similarly, the bank‟s HMDA lending to moderate-income
borrowers (16.3 percent) is slightly less than the percentage of moderate-income borrowers
within the assessment area (18.7 percent), but higher than aggregate lending to moderate-income
borrowers (15.7 percent). Therefore, the bank‟s level of lending to LMI borrowers within the
assessment area is good.
28
Arvest Bank
January 10, 2011
Next, small business loans were reviewed to determine the bank‟s lending levels to businesses of
different sizes. The following table shows the distribution of small business loans by loan
amount and business revenue size.13
Lending Distribution by Business Revenue Level
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
Loan Amounts in $000s
TOTAL
<$100
>$100<$250
>$250 <$1,000
1,747
317
281
2,345
70.5%
12.8%
11.3%
94.7%
38
32
62
132
1.5%
1.3%
2.5%
5.3%
1,785
349
343
2,477
72.1%
14.1%
13.8%
100%
The bank originated a substantial majority of its small business loans (94.7 percent) to businesses
with revenues of $1 million or less. The highest concentration of these loans was for loan
amounts of $100,000 or less, which further demonstrates the bank‟s willingness to make credit
available to small businesses in the assessment area. According to Dun & Bradstreet, 90.2
percent of businesses reporting for 2009 had revenues of $1 million or less. In addition, the
bank‟s level of lending to small businesses surpasses the 2009 aggregate lending level of 13.3
percent. Therefore, the bank‟s level of lending to small businesses in the assessment area is
excellent.
13
This analysis included 2,491 small business loans; however, 14 of these loans were removed from the sample
because information related to business revenue size was not available.
29
Arvest Bank
January 10, 2011
Finally, small farm loans were reviewed to determine the bank‟s lending levels to farms of
different sizes. The following table shows the distribution of small farm loans by loan amount
and farm revenue size.
Lending Distribution by Farm Revenue Level
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
619
69
16
704
87.6%
9.8%
2.3%
99.6%
1
1
1
3
0.1%
0.1%
0.1%
0.4%
620
70
17
707
87.7%
9.9%
2.4%
100%
Of the 707 small farm loans the bank made in this assessment area, 99.6 percent were originated
to farms with revenues of $1 million dollars or less. Further, the highest concentration of these
loans was in loan amounts of $1 million or less, which further demonstrates the bank‟s
willingness to make credit available to small farms in the assessment area. According to Dun &
Bradstreet, 97.7 percent of farms in the assessment area reported revenues of $1 million or less.
In addition, the bank‟s level of lending to small farms is significantly higher than the 2009 CRA
aggregate percentage of lending to small farms, 67.9 percent. Therefore, Arvest Bank‟s lending
to small farms is excellent.
Arvest Bank continues to be a leader in making community development loans in the
Fayetteville MSA Assessment Area. During the review period, the bank originated or renewed
12 community development loans totaling $14.1 million within this assessment area. Ten of the
loans financed construction or renovation projects providing affordable housing to LMI
individuals within the assessment area. Two of the loans were for community services targeted
to LMI individuals within the assessment area.
30
Arvest Bank
January 10, 2011
INVESTMENT TEST
Arvest Bank‟s performance under the Investment Test is rated outstanding for the Fayetteville
MSA. The bank made an excellent level of qualified community development investments and
grants. The bank makes significant use of complex investments to support community
development initiatives, and the bank exhibits excellent responsiveness to credit and community
development needs in the Fayetteville MSA Assessment Area.
Investment and Grant Activity
Arvest Bank has an excellent level of qualified community development investments and grants
within the Fayetteville MSA. As of December 31, 2010, the bank had a balance of $12.5 million
in qualified investments, representing an increase of $3.3 million (35.9 percent) since the last
CRA evaluation. The bank has $6.9 million invested in MBS ($1.5 million in new investments
and $5.4 million in previous review period investments still outstanding) that finance affordable
housing. In addition, the bank has investments in projects associated with Low Income Housing
Tax Credits (LIHTCs) that total $5.6 million. Arvest Bank also made a significant level of
community development grants within the Fayetteville MSA—210 grants totaling $410,742.
Among these numerous contributions were significant donations to schools serving a majority of
LMI students, affordable housing organizations, and community service organizations that target
children from LMI families.
Community Development Initiatives
In the Fayetteville MSA, the bank makes significant use of investments in LIHTCs. These
investments fund the construction of new rental housing and rehabilitation of existing housing
for low-income households.
Responsiveness to Credit and Community Development Needs
Arvest Bank exhibits excellent responsiveness to credit and community development needs.
Community contacts noted that the major credit needs in this assessment area are flexible options
for residential real estate loans and commercial operating lines-of-credit. The bank‟s previously
mentioned investments and grants target these needs by providing liquidity in the secondary
market for home loans made to LMI borrowers and by making capital available for low-income
housing projects.
31
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s Service Test rating in the Fayetteville MSA is low satisfactory. Delivery systems
are accessible to all geographies and individuals of different income levels in the Fayetteville
MSA Assessment Area, and the bank‟s record of opening and closing branches has generally not
adversely affected the accessibility of its delivery systems to LMI geographies and/or LMI
individuals. Business hours and services do not vary in a way that inconveniences LMI
geographies and/or LMI individuals, and bank personnel provides an adequate level of
community development services in this assessment area.
Arvest Bank operates 52 branch facilities, including the main office, within the Fayetteville
MSA Assessment Area. The following table illustrates the distribution of these facilities by
income level of geography, as compared to key assessment area demographics.
Dataset
Branches
Branch Distribution by Geography Income Level
LowModerate- MiddleUpper- Unknown
0
7
37
8
0
0.0%
13.5%
71.2%
15.4%
0.0%
TOTAL
52
100%
Census Tracts
2.9%
16.2%
67.6%
13.2%
0.0%
100%
Household
Population
2.7%
13.1%
68.8%
15.5%
0.0%
100%
As illustrated in the above table, Arvest Bank‟s branches in moderate-income census tracts
represent 13.5 percent of all facilities in the Fayetteville MSA Assessment Area. This dispersion
of service delivery systems in moderate-income geographies is in line with moderate-income
demographics. While the bank does not have any branches in low-income geographies, the bank
does have facilities located within close proximity of the two low-income geographies in this
assessment area. Based on this information, Arvest Bank‟s delivery systems are accessible to
geographies and individuals of different income levels in the Fayetteville MSA.
During the review period, the bank did not add any branches and closed three branches in the
Fayetteville MSA Assessment Area. The bank closed one drive-up facility in a low-income
census tract, one drive-up facility in a middle-income census tract, and one full-service branch in
an upper-income census tract. While this activity reflects a slight decrease in overall service
accessibility, this minor consolidation did not disproportionally affect LMI areas or customers.
Consequently the bank‟s record of opening and closing branches in this assessment area has
generally not adversely affected the accessibility of delivery systems, particularly to LMI
geographies and/or LMI individuals.
32
Arvest Bank
January 10, 2011
Reasonableness of Business Hours and Services in Meeting Assessment Area Needs
Business hours and banking products and services are relatively consistent across all branches in
the Fayetteville MSA Assessment Area. Most branches have Saturday operating hours and offer
extended hours of operations in lobby and drive-up facilities at some point during the week.
Most drive-up facilities remain open until 6 p.m., Monday through Friday, and are open until
noon on Saturdays. All branches offer the same standard products, including low-cost checking
and savings accounts, certificates of deposit, real estate and consumer loans, and other services.
Therefore, bank services do not vary in a way that inconveniences certain segments of this
assessment area, particularly LMI geographies and/or LMI individuals.
Arvest Bank staff members within the Fayetteville MSA provide an adequate level of
community development services. Six bank employees provide financial expertise to community
development organizations on an ongoing basis. Two of these organizations assist schools with
a large proportion of LMI students, two organizations assist low-income students in obtaining
higher education scholarships, one organization assists the needy in the area, and one
organization is part of a government plan for the revitalization and stabilization of a moderateincome area.
33
Arvest Bank
January 10, 2011
FORT SMITH MULTISTATE MSA14
CRA RATING FOR FORT SMITH ARKANSAS-OKLAHOMA MSA: SATISFACTORY
Low Satisfactory
Low Satisfactory
High Satisfactory
Major factors supporting the institution‟s Fort Smith Arkansas-Oklahoma MSA (Fort Smith
Arvest Bank‟s lending levels reflect good responsiveness to the credit needs of the Fort
Smith MSA.
The bank‟s overall geographic distribution of loans reflects good penetration throughout the
Fort Smith MSA.
The bank did not make any community development loans within the Fort Smith MSA,
which is reflective of past performance.
The bank makes an adequate level of qualified community development investments and
grants within the Fort Smith MSA.
Service delivery systems are readily accessible to geographies and individuals of different
income levels in the Fort Smith MSA; further, changes in branch locations have not
adversely affected the accessibility of delivery systems, particularly to LMI geographies
Arvest Bank personnel provides a relatively high level of community development services
within the Fort Smith MSA.
14
This rating reflects performance within the multistate MSA. The Arkansas and Oklahoma statewide evaluations
are adjusted and do not reflect performance in the parts of those states contained within the Fort Smith MSA.
34
Arvest Bank
January 10, 2011
Arvest Bank has one assessment area in the Fort Smith MSA, which includes the entire
multistate MSA. Arvest Bank‟s performance within the Fort Smith MSA was reviewed using
full-scope examination procedures, and scoping considerations applicable to the review of this
assessment area are consistent with the overall CRA examination scope as presented in the
Institution, Scope of Examination section. However, as the bank had a relatively low volume of
small farm loans in this assessment area, performance based on this loan category received less
weight when making overall lending performance conclusions for this MSA. Finally, this
evaluation included information obtained through four community contact interviews completed
in the Fort Smith MSA, including one completed as part of this review. The community contact
completed as part of this review took place with a community development professional who
specializes in personal wealth management.15
DESCRIPTION OF INSTITUTION’S OPERATIONS IN FORT SMITH MSA
Bank Structure
Arvest Bank operates 17 of its 239 branches (7.1 percent) within the Fort Smith MSA
Assessment Area. Of the 17 branches, three are in moderate-income census tracts, 11 are in
middle-income census tracts, and three are located in upper-income census tracts (there are no
low-income census tracts in the Fort Smith MSA). During this review period, the bank opened
two branches and closed one branch in this assessment area. Based on this branch network and
other service delivery systems, the bank is well positioned to deliver financial services to
substantially all of the Fort Smith MSA Assessment Area.
This assessment area is a competitive banking market with a total of 23 FDIC-insured
institutions operating within the Fort Smith MSA, based on the FDIC Deposit Market Share
Report as of June 30, 2010. Of the 23 financial institutions with an office in the Fort Smith
MSA, Arvest Bank ranked 3rd with a deposit market share of 11.3 percent. Based on this
information, Arvest Bank deposits held at branches in this assessment area account for 5.2
percent of the bank‟s total deposits.
The Fort Smith MSA is a five-county multistate MSA including three counties in Arkansas and
two counties in Oklahoma. Specifically, the Arkansas portions of the multistate MSA include
Crawford, Franklin, and Sebastian counties. The Oklahoma portion of the multistate MSA
consists of Le Flore and Sequoyah counties. The multistate MSA is located along the western
border of Arkansas and the eastern border of Oklahoma.
15
Operations.
35
Arvest Bank
January 10, 2011
Based on 2000 census data, the assessment area had a total population of 273,170. Although a
significant portion of the population is concentrated in Sebastian County (115,071), several other
counties have sizeable populations. Crawford County had a population of 53,247, followed by
Le Flore County at 48,109, Sequoya County at 38,972, and Franklin County at 17,771.
According to U.S. Census Bureau estimates as of July 2009, the population in the Fort Smith
MSA is growing. The total MSA population in 2009 was estimated at 293,063. This marks a
total MSA population increase of approximately 7.3 percent since the 2000 census.
programs (specifically, programs targeting down-payment assistance such as those related to
individual development accounts), homelessness/foreclosure prevention programs, and financial
education. Further, as the Fort Smith MSA is an environment with significant need, coupled
with an ample source of community development intermediaries (such as nonprofit agencies,
higher education institutions, and government assistance entities), there is ample community
development opportunity available for financial institution participation.
The Fort Smith MSA consists of 52 geographies. As of 2009, the HUD estimated median family
income for the Fort Smith MSA was $46,500. The following table summarizes the distribution
of geographies by income level and the family population of those census tracts within the
assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
0
4
40
8
0
52
7.7%
76.9%
15.4%
3,206
62,701
9,548
4.2%
83.1%
12.7%
0.0%
0
0.0%
36
0.0%
0
0.0%
100%
75,455
100%
Arvest Bank
January 10, 2011
as family population income characteristics for the states of Arkansas and Oklahoma.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
14,885
13,479
17,310
29,781
75,455
19.7%
17.9%
22.9%
39.5%
100%
148,233
131,570
163,567
292,693
736,063
20.1%
17.9%
22.2%
39.8%
100%
187,672
168,813
200,838
370,380
927,703
20.2%
18.2%
21.6%
39.9%
100%
Assessment Area
Arkansas
Oklahoma
Housing costs in the Fort Smith MSA Assessment Area appear to be affordable relative to
comparable state data. The Fort Smith MSA had a housing affordability ratio of 49.0 percent as
of the 2000 census, indicating that housing affordability in the assessment area is similar to the
state of Arkansas (47.0 percent) and the state of Oklahoma (49.0 percent). Of the five MSA
counties, housing is more affordable in Franklin County and Le Flore County (both at 52.0
percent) than Crawford County, Sebastian County, and Sequoyah County (48.0, 47.0, and 48.0
percent, respectively). The median housing value in the assessment area was $63,462, which is
lower than the figures for the state of Arkansas ($67,400) and the state of Oklahoma ($67,700).
Median gross monthly rent in the Fort Smith MSA is also less ($405) than both the state of
Arkansas ($453) and the state of Oklahoma ($456).
37
Arvest Bank
January 10, 2011
agricultural entities operating within the Fort Smith MSA. Fort Smith is a major manufacturing
hub in Arkansas. The following table depicts employment levels by industry, comparing the Fort
Smith MSA economy to the state of Arkansas and the state of Oklahoma using the “Location
Quotient” measure.16
Fort Smith MSA - Employment by Industry
Industry
Construction
Manufacturing
Information
Other Services
TOTAL
3,086
4,808
21,825
23,714
1,244
4,016
10,508
15,591
9,257
2,038
% of
Total
3.2%
5.0%
22.7%
24.7%
1.3%
4.2%
10.9%
16.2%
9.6%
2.1%
96,087
100%
Employment
LQ Arkansas
1.44
0.90
1.29
0.99
0.74
0.79
0.90
0.95
0.90
0.80
LQ Oklahoma
0.70
0.85
2.06
1.03
0.55
0.62
0.77
0.99
0.81
0.68
N/A
As displayed in the previous table, the largest industries in the Fort Smith MSA are trade,
transportation, and utilities; manufacturing; and education and health services. The industry mix
is similar to the state of Arkansas, with a greater reliance on natural resources and mining and
manufacturing. The industry mix varies significantly from the state of Oklahoma, most notably
with a greater reliance on manufacturing and less reliance on information-related industry.
The recent annual average unemployment rates for the Fort Smith MSA (4.9 percent in 2008 and
7.9 percent in 2009) were similar to the unemployment rate for the state of Arkansas (5.3 percent
in 2008 and 7.4 percent in 2009), but higher than the state of Oklahoma (3.7 percent in 2008 and
6.6 percent in 2009).17 Similar to the state of Arkansas and the state of Oklahoma,
unemployment in the Fort Smith MSA generally rose in 2010 and was projected to be at 9.2
percent in January 2011—higher than the preliminary figure for the state of Arkansas (8.7
percent) and significantly higher than the state of Oklahoma (6.9 percent).
16
17
38
Arvest Bank
January 10, 2011
The community contacts characterized the Fort Smith MSA population as growing and aging, as
younger entrants to the job market often leave the Fort Smith area in search of better
employment opportunities. Though the Fort Smith MSA has weathered the recent economic
turmoil better than some portions of Arkansas, the community contacts mentioned that the area
has recently seen a sharp increase in the number of foreclosures, yet, affordable housing appears
to be sufficient for current demand.
Contacts noted that despite the current economic situation in which banks are tightening credit
standards, it appears that banks in the area are doing a reasonable job of serving the community‟s
credit needs. In general, local financial institutions are active in many community initiatives,
such as chambers of commerce and housing-related advisory boards. Additionally, the
community contacts noted that many lenders, including Arvest Bank, participate in down
payment assistance programs benefiting home buyers. Overall, community contact information
revealed that the local financial institutions are service-oriented and cater to the needs of the
community.
39
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN FORT SMITH MSA
LENDING TEST
Arvest Bank‟s Lending Test performance in the Fort Smith MSA is rated low satisfactory.
Lending levels reflect good responsiveness to the Fort Smith MSA Assessment Area credit
needs. The geographic distribution of loans reflects good penetration throughout the assessment
area. The loan distribution by borrower‟s income/revenue profile reflects excellent penetration
among customers of different income levels and businesses/farms of different sizes. However,
the bank‟s continued lack of community development lending activity in this assessment area
negatively impacted the bank‟s overall Lending Test rating.
Lending Activity
The bank‟s lending levels within the Fort Smith MSA reflect good responsiveness to assessment
area credit needs based upon the lending activity analyzed under the Lending Test. This lending
Loan Type
Home Improvement
#
%
$(000s)
%
454
24.9%
$13,240
9.8%
71
3.9%
$5,227
3.9%
9
0.5%
$2,165
1.6%
382
20.9%
$20,253
15.0%
Total HMDA related
916
50.2%
$40,885
30.2%
Small Business
827
45.3%
$86,675
64.0%
82
4.5%
$7,872
5.8%
1,825
100%
$135,432
100%
Home Purchase
Refinancing
Small Farm
TOTAL LOANS
40
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Fort Smith MSA section, this
assessment area has zero low-income census tracts and four moderate-income census tracts,
representing 7.7 percent of all assessment area census tracts. Overall, based on lending activity
from all three loan categories reviewed, the geographic distribution of loans reflects good
penetration throughout the assessment area, including the moderate-income census tracts. The
following table displays the geographic distribution of HMDA loans in comparison to owneroccupied housing demographics for the assessment area.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
17
301
84
0
4.2%
74.9%
20.9%
17
684
197
1.9%
76.2%
21.9%
121
30
78.6%
19.5%
3
6
0
33.3%
66.7%
0.0%
40
1,112
311
0.0%
2.7%
76.0%
21.3%
0.0%
100%
0.0%
3.5%
84.0%
12.5%
0.0%
100%
0.0%
0
0.0%
0
0.0%
0
3
1.9%
0.0%
0
0.0%
0
0.0%
0
402
100%
898
100%
154
100%
9
Multi-Family
0.0%
TOTAL
LOANS
Owner Occupied
Housing
0
0.0%
0
100%
1,463
The analysis of the bank‟s 2009 HMDA-lending activity revealed that lending in moderateincome census tracts is good. While the bank‟s loan penetration among moderate-income census
tracts (2.7 percent) is below the comparable owner-occupied housing figure (3.5 percent), it is
above that of other lenders, based upon 2009 HMDA aggregate lending performance in
moderate-income census tracts (2.3 percent).
41
Arvest Bank
January 10, 2011
Next, the bank‟s geographic distribution of small business loans was reviewed, which is
Dataset
Small Business
Loans
Business
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
26
239
152
0
417
0.0%
6.2%
57.3%
36.5%
0.0%
100%
0.0%
8.7%
75.2%
16.1%
0.0%
100%
While below comparison data levels, the geographic distribution of the bank‟s small business
loans reflects adequate penetration throughout the assessment area, including moderate-income
geographies. The percentage of small business loans in moderate-income tracts (6.2 percent) is
below but within adequate range of the estimated percentage of businesses located in moderateincome census tracts (8.7 percent) and the 2009 CRA aggregate lending level in moderateincome census tracts (7.9 percent).
42
Arvest Bank
January 10, 2011
Finally, the geographic distribution of small farm loans is displayed in the following table in
comparison to the location of farms throughout the assessment area.
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
30
4
0
34
0.0%
0.0%
88.2%
11.8%
0.0%
100%
0.0%
0.9%
92.1%
6.9%
0.0%
100%
As displayed in the preceding table, the bank had a relatively low level of small farm lending in
this assessment area. However, based on the limited loan activity available for review, the
geographic distribution of small farm loans is adequate. While the bank did not make any small
farm loans in moderate-income census tracts, this is not considered poor performance in light of
the very small percentage of farms located in moderate-income census tracts (0.9 percent). The
2009 CRA aggregate lending level in moderate-income census tracts is even smaller (0.4
percent). The strong majority of the bank‟s small farms loans (88.2 percent) was made in
middle-income census tracts, which is in line with the percentage of farms located in middleincome census tracts (92.1 percent).
43
Arvest Bank
January 10, 2011
reported loans by the income level of the borrower in comparison to family population data.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
33
110
111
133
15
402
8.2%
27.4%
27.6%
33.1%
3.7%
100%
65
152
194
474
13
898
7.2%
16.9%
21.6%
52.8%
1.4%
100%
10
24
31
82
7
154
6.5%
15.6%
20.1%
53.2%
4.5%
100%
0
0
0
0
9
9
0.0%
0.0%
0.0%
0.0%
100.0%
100%
108
286
336
689
44
1,463
7.4%
19.5%
23.0%
47.1%
3.0%
100%
19.7%
17.9%
22.9%
39.5%
0.0%
100%
Multi-Family
TOTAL
LOANS
Families
Based on the above table, the bank‟s level of lending to low-income borrowers (7.4 percent) is
lower than the low-income family population (19.7 percent). However, the bank‟s level of
lending is in line with the 2009 HMDA aggregate lending level to low-income borrowers (7.3
percent). Furthermore, the bank‟s HMDA lending to moderate-income borrowers (19.5 percent)
is higher than the percentage of moderate-income borrowers within the assessment area (17.9
percent) and higher than aggregate lending to moderate-income borrowers (17.0 percent).
Therefore, the bank‟s overall level of lending to LMI borrowers is good.
44
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250 <$1,000
302
44
29
375
73.3%
10.7%
7.0%
91.0%
20
6
11
37
4.9%
1.5%
2.7%
9.0%
322
50
40
412
78.2%
12.1%
9.7%
100%
The bank‟s level of lending to small businesses within the assessment area is excellent. The
bank originated a substantial majority of its small business loans (91.0 percent) to businesses
with revenues of $1 million or less. The highest concentration of these loans was for loan
available to small businesses. According to Dun & Bradstreet estimates, 88.3 percent of
assessment area businesses had revenues of $1 million or less. In addition, the bank‟s level of
lending to small businesses surpasses the 2009 CRA aggregate lending level of 25.6 percent.
18
This analysis included 417 small business loans; however, five of these loans were removed from the sample
45
Arvest Bank
January 10, 2011
Small farm loans were reviewed to determine the bank‟s lending levels to farms of different
sizes. The following table shows the distribution of small farm loans by loan amount and farm
revenue size.
Gross Revenue
$1 Million or Less
Greater Than $1 Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
25
5
4
34
73.5%
14.7%
11.8%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
25
5
4
34
73.5%
14.7%
11.8%
100%
As previously noted, the bank had a relatively low level of small farm lending in this assessment
area. However, based on the limited loan activity available for review, the distribution of small
farm loans by borrower‟s profile is excellent. All small farm loans made in this assessment area
were originated to farmers with revenues of $1 million or less. The highest concentration of
these loans was in loan amounts of $100,000 or less, which further demonstrates the bank‟s
willingness to make credit available to small farms in the assessment area. According to Dun &
Bradstreet, 97.8 percent of farms in the assessment area reported revenues of $1 million or less.
The bank‟s farm lending is also higher than 2009 CRA aggregate data, which indicates that 82.9
percent of reported small farm loans were to small farms.
Arvest Bank did not make any community development loans in the Fort Smith MSA during this
reviewed period, as was the case for the bank‟s previous two CRA evaluations.
46
Arvest Bank
January 10, 2011
INVESTMENT TEST
Overall, Arvest Bank‟s performance under the Investment Test is rated low satisfactory for the
Fort Smith MSA. The bank makes an adequate level of qualified community development
investments and grants, exhibiting adequate responsiveness to credit and community
development needs in the Fort Smith MSA Assessment Area. As of this evaluation date, the
bank had a balance of $1.1 million in qualified investments attributable to this assessment area
($0.3 million in new investments and $0.8 million in previous review period investments still
outstanding), which represents a decrease of $0.4 million (26.7 percent) since the last CRA
evaluation. All of the bank‟s community development investments in the Fort Smith MSA are in
MBS that finance affordable housing. Additionally, Arvest Bank made 60 grants totaling
$236,293 throughout the assessment area during this review period. Among the numerous
qualifying contributions were significant donations to schools serving a majority of LMI
students, affordable housing organizations, and community service organizations that target
47
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s Service Test rating in the Fort Smith MSA is high satisfactory. Service delivery
systems are readily accessible to geographies and individuals of different income levels in the
Fort Smith MSA Assessment Area, and the bank‟s record of opening and closing branches has
not adversely affected the accessibility of its delivery systems to LMI geographies and/or LMI
individuals. Business hours and services do not vary in a way that inconveniences LMI
geographies and/or LMI individuals, and bank personnel provides a relatively high level of
community development services in the Fort Smith MSA.
Arvest Bank operates 17 branch facilities within the Fort Smith MSA Assessment Area. The
following table illustrates the distribution of these facilities by income level of the geography, as
compared to key assessment area demographics.
Dataset
Branches
0
3
11
3
0
0.0%
17.6%
64.7%
17.6%
0.0%
TOTAL
17
100%
Census Tracts
0.0%
7.7%
76.9%
15.4%
0.0%
100%
Household
Population
0.0%
4.8%
82.1%
13.1%
0.0%
100%
Based on the information in the preceding table, Arvest Bank‟s service delivery systems are
readily accessible to the geographies and individuals of different income levels in the Fort Smith
MSA Assessment Area. Of the 17 facilities the bank operates in this assessment area, 17.6
percent are located in moderate-income census tracts, which is above both the percentage of
moderate-income census tracts (7.7 percent) and the percentage of moderate-income households
in the assessment area (4.8 percent).
During the review period, the bank opened two full-service branches in middle-income
geographies and closed one full-service branch in a middle-income geography. Consequently
the bank‟s record of opening and closing branches in the Fort Smith MSA Assessment Area has
not adversely affected the accessibility of its delivery systems, particularly to LMI geographies
48
Arvest Bank
January 10, 2011
the Fort Smith MSA Assessment Area. Most branches have Saturday operating hours and offer
Most drive-thru facilities remain open until 6 p.m., Monday through Friday, and are open until
Arvest Bank staff members within the Fort Smith MSA provides a relatively high level of
community development services, as nine bank employees provide financial expertise to four
community development organizations on an ongoing basis. Six employees work with an
organization that provides affordable housing for LMI families, two work with organizations
assisting schools with a majority of LMI students, and one employee works with an organization
assisting low-income students to obtain higher education scholarships.
49
Arvest Bank
January 10, 2011
KANSAS CITY MULTISTATE MSA19
CRA RATING FOR KANSAS CITY KANSAS-MISSOURI MSA: SATISFACTORY
High Satisfactory
Low Satisfactory
Low Satisfactory
Major factors supporting the institution‟s Kansas City Kansas-Missouri MSA (Kansas City
Arvest Bank‟s lending levels reflect adequate responsiveness to the credit needs of the
Kansas City MSA.
The bank‟s overall geographic distribution of loans reflects good penetration throughout the
Kansas City MSA.
The distribution of loans by borrower‟s income/revenue profile reflects good penetration
among borrowers of different income levels and businesses of different sizes.
The bank makes a relatively high level of community development loans within this
assessment area.
The bank makes an adequate level of qualified community development investments and
grants within the Kansas City MSA.
Service delivery systems are reasonably accessible to geographies and individuals of
different income levels in the Kansas City MSA.
19
This rating reflects performance within the multistate MSA. The Missouri and Kansas statewide evaluations are
adjusted and do not reflect performance in the parts of those states contained within the multistate MSA.
50
Arvest Bank
January 10, 2011
Arvest Bank has one assessment area in the Kansas City MSA, which includes the entire
multistate MSA. Arvest Bank‟s CRA performance within the Kansas City MSA was reviewed
using full-scope examination procedures, and scoping considerations applicable to the review of
this assessment area are consistent with the overall CRA examination scope as presented in the
Institution, Scope of Examination section. However, as previously noted, the bank entered this
market largely through a 2009 bank acquisition (followed by subsequent acquisition activity),
and banking operations had yet to be fully established during this review period. Consequently,
overall lending volume in the Kansas City MSA was relatively low, and the bank had no small
farm lending activity during the review period. Finally, information obtained through seven
community contact interviews completed in the Kansas City MSA was considered as a part of
this evaluation.20
DESCRIPTION OF INSTITUTION’S OPERATIONS IN KANSAS CITY MSA
Bank Structure
Arvest Bank operates ten of its 239 branches (4.2 percent) within the Kansas City MSA
Assessment Area, all of which were added during this review period (the bank did not close any
branch offices). Of the ten branches, none are located in low-income census tracts, one is in a
moderate-income census tract, three are in middle-income census tracts, and six are located in
upper-income census tracts. Based on the number and location of these branches in relation to
the size of the Kansas City MSA, Arvest Bank is not able to effectively serve all parts of this
assessment area. More specifically, the bank‟s current branch network is centered in the
southern core of the MSA, putting the bank at a competitive disadvantage in the southernmost,
easternmost, and northernmost counties of the MSA.
This assessment area is a highly competitive banking market, with a total of 147 FDIC-insured
institutions operating within the MSA, based on the FDIC Deposit Market Share Report as of
June 30, 2010. Of the 147 financial institutions with an office in the Kansas City MSA, Arvest
Bank ranked 27th with a deposit market share of 0.9 percent. Based on this information, Arvest
Bank deposits held at branches throughout the Kansas City MSA represent 4.0 percent of the
bank‟s total deposits.
20
Operations.
51
Arvest Bank
January 10, 2011
The Kansas City MSA is a 15-county multistate MSA, including six counties in Kansas and nine
counties in Missouri, covering a large portion of the border between Kansas and Missouri. The
Kansas counties in the multistate MSA are Franklin, Johnson, Leavenworth, Linn, Miami, and
Wyandotte. The Missouri portion of the multistate MSA consists of Bates, Caldwell, Cass, Clay,
Clinton, Jackson, Lafayette, Platte, and Ray counties. Based on 2000 census data, the
assessment area had a total population of 1,836,038. A significant portion of the population is
concentrated in Jackson County, Missouri (654,880), and Johnson County, Kansas (451,086).
The remaining eight Missouri counties report populations ranging from 8,969 to 184,006. The
remaining five counties in Kansas have populations ranging from 9,570 to 157,882. The total
MSA population in 2009 was estimated at 2,067,585. This marks a total MSA population
increase of approximately 12.6 percent since the 2000 census.
programs (specifically, subsidized programs aimed at assisting first time homebuyers) and
community development participation, financial and otherwise, aimed at the rehabilitation of
nuisance properties. Further, as the Kansas City MSA is an environment with significant need,
coupled with an ample source of community development intermediaries (such as nonprofit
agencies, higher education institutions, and government assistance entities), there is a high level
of community development opportunity available for financial institution participation.
The Kansas City MSA consists of 516 geographies. As of 2009, the HUD estimated median
family income for the Kansas City MSA was $70,400. The following table summarizes the
distribution of geographies by income level and the family population of those census tracts
within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
46
134
203
121
12
516
8.9%
26.0%
39.3%
23.4%
2.3%
100%
20,107
95,578
229,685
140,599
0
485,969
4.1%
19.7%
47.3%
28.9%
0.0%
100%
52
Arvest Bank
January 10, 2011
The following table displays the distribution of families, by income level, that reside in this
assessment area as well as the statewide percentages for Kansas and Missouri.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
88,857
91,285
114,883
190,944
485,969
18.3%
18.8%
23.6%
39.3%
100%
117,432
130,953
171,758
286,643
706,786
16.6%
18.5%
24.3%
40.6%
100%
282,730
278,477
345,089
580,250
1,486,546
19.0%
18.7%
23.2%
39.0%
100%
Kansas
Missouri
The Kansas City MSA Assessment Area had a housing affordability ratio of 43.0 percent as of
the 2000 census, which indicates significantly less affordability than the state of Kansas overall
(50.0 percent) but similar affordability to the state of Missouri (43.0 percent). Housing
affordability varied significantly by county in the assessment area. The least affordable county
was Miami County, Kansas (40.0 percent), while Wyandotte County, Kansas, was the most
affordable (63.0 percent). The median housing value in the assessment area was $102,876,
which is much higher than the state of Kansas ($81,000) and the state of Missouri ($86,900).
Much like the affordability ratio, the median housing value also varied significantly by county.
The median housing value in Johnson County, Kansas, was $149,300, while the median housing
value in Wyandotte County, Kansas, was only $53,400. Median gross monthly rent in the
Kansas City MSA was also significantly higher at $572 than both the state of Kansas ($498) and
the state of Missouri ($484). Based on this information, housing costs in the Kansas City MSA
appear to be less affordable relative to overall data for the state of Kansas and the state of
Missouri.
53
Arvest Bank
January 10, 2011
According to 2009 Dun & Bradstreet data, there were 86,692 business entities and 2,317
agricultural entities operating within the Kansas City MSA. The area‟s largest private employer
is a major international telecommunications company. Numerous other national and international
companies are headquartered in the Kansas City MSA. The following table depicts employment
levels by industry, comparing the Kansas City MSA economy to the state of Kansas and the state
of Missouri using the “Location Quotient” measure. 21
Kansas City MSA - Employment by Industry
Industry
Construction
Manufacturing
Information
Other Services
TOTAL
1,989
42,104
73,460
191,033
ND
70,131
ND
118,981
93,518
27,043
% of
Total
0.3%
5.3%
9.3%
24.1%
ND
8.8%
ND
15.0%
11.8%
3.4%
793,348
100%
Employment
LQ Kansas
0.15
0.97
0.59
1.03
ND
1.34
ND
0.92
1.10
0.99
LQ Missouri
0.36
0.97
0.79
1.02
ND
1.23
ND
0.87
0.94
0.88
N/A
As displayed in the previous table, the largest industries in the Kansas City MSA are Trade,
transportation, and utilities; and education and health services. The industry mix is similar to
both the state of Kansas and the state of Missouri, with a greater reliance on financial activities
and less reliance on natural resources and mining.
The recent annual average unemployment rates for the Kansas City MSA (5.8 percent in 2008
and 8.6 percent in 2009) were higher than the unemployment rates for the state of Kansas (4.5
percent in 2008 and 7.1 percent in 2009), but less than the state of Missouri (6.1 percent in 2008
and 9.3 percent in 2009).22 While monthly 2010 unemployment rates for the Kansas City MSA
varied above and below the 2009 annual average rate, the projection for January 2011 (9.2
percent) indicates unemployment continues to rise.
21
22
Source: 2009 Bureau of Labor Statistics, U.S. Department of Labor (ND = “not disclosable”)
54
Arvest Bank
January 10, 2011
Community contacts noted that there is a need for affordable housing options in the urban areas
of Kansas City, which is further exacerbated by the weak economy and related credit flow
restrictions. Banks are tightening their underwriting standards, making it more difficult to obtain
financing for housing. In addition, the housing market remains slow, and potential
unemployment fears prevent many borrowers from pursuing additional debt. Without subsidized
lending assistance, such as first-time homebuyers programs, the LMI population has limited
options to attain homeownership. Such individuals that are successful are mainly moving out of
the urban core and finding affordable homes in the north and south Kansas City areas, where the
housing stock is in better condition. Even if there is an acceptable affordable house in the urban
core, considerable property risk remains, as related to surrounding lots in need of rehabilitation
(including foreclosures and vacant lots).
Community contacts also stated that local banks appear to be serving the credit needs of the
community, though there is always room for advancement. Besides housing-related credit, small
consumer loans for personal expenses are a credit need in the area. Although banks are limited
on what they can do, more involvement in subsidized lending would help the area. First-time
homebuyers' programs, Title 1 home improvement loans, grant-writing assistance, and other
investments in the area would be beneficial. Lastly, according to community contacts, marketing
efforts made primarily by suburban banks could be improved to better reach LMI individuals
residing in Kansas City‟s urban core.
55
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN KANSAS CITY
MSA
LENDING TEST
Arvest Bank‟s Lending Test performance in the Kansas City MSA is rated high satisfactory.
Lending levels reflect adequate responsiveness to assessment area credit needs. The geographic
distribution of loans reflects good penetration throughout the assessment area. The loan
distribution by borrower‟s income/revenue profile reflects good penetration among customers of
different income levels and businesses of different sizes. In addition, Arvest Bank makes a
relatively high level of community development loans in the Kansas City MSA Assessment
Area.
Lending Activity
The bank‟s lending levels within the Kansas City MSA reflect adequate responsiveness to
assessment area credit needs based upon the lending activity analyzed under the Lending Test.
This lending activity is displayed by loan type in the following table:
Loan Type
#
%
$(000s)
%
Home Improvement
2
1.5%
$101
0.2%
Home Purchase
8
6.0%
$2,631
4.9%
2
1.5%
$16,635
31.1%
Refinancing
6
4.5%
$247
0.5%
18
13.4%
$19,614
36.7%
116
86.6%
$33,875
63.3%
0
0.0%
$0
0.0%
134
100%
$53,489
100%
Total HMDA related
Small Business
Small Farm
TOTAL LOANS
As the bank had not begun operations in the Kansas City MSA market until the end of 2009, the
lending activity in the table above is reflective of this minimal bank presence during the review
period. Consequently, these figures are significantly lower than the bank‟s lending levels in
other assessment areas. However, in light of the performance context as related to the timing of
the bank‟s entry into this market, the bank‟s lending activity levels are adequate.
56
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Kansas City MSA section, this
assessment area has 46 low-income census tracts and 134 moderate-income census tracts,
from both loan categories reviewed, the geographic distribution of loans reflects good
penetration throughout the assessment area, including the LMI tracts. The following table
displays the geographic distribution of HMDA loans in comparison to owner-occupied housing
demographics for the assessment area.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
2
3
7
0
12
0.0%
16.7%
25.0%
58.3%
0.0%
100%
0
2
5
6
0
13
0.0%
15.4%
38.5%
46.2%
0.0%
100%
0
0
0
1
0
1
0.0%
0.0%
0.0%
100.0%
0.0%
100%
0
0
0
2
0
2
0.0%
0.0%
0.0%
100.0%
0.0%
100%
0
4
8
16
0
28
0.0%
14.3%
28.6%
57.1%
0.0%
100%
2.9%
18.1%
47.9%
31.1%
0.0%
100%
Multi-Family
TOTAL
LOANS
Owner Occupied
Housing
As displayed in the preceding table, the bank had a low level of HMDA-lending activity in this
assessment area, which does not provide for a meaningful analysis. However, based on the
limited activity available for review, the bank‟s geographic distribution of loans is adequate.
While the bank did not make any loans in low-income census tracts, there is a relatively small
percentage of owner-occupied homes in low-income census tracts (2.9 percent). Further, 2009
HMDA aggregate lending data indicate other lenders made less than one percent of HMDA loans
in low-income census tracts. Bank lending in moderate-income census tracts (14.3 percent) is
good. While below the percentage of owner-occupied housing in moderate-income census tracts
(18.1 percent), the bank‟s percentage of loans in moderate-income census tracts is significantly
higher than other lenders based on the 2009 HMDA aggregate percentage (8.3 percent).
57
Arvest Bank
January 10, 2011
Dataset
Small Business
Loans
Business
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
5
17
21
50
0
93
5.4%
18.3%
22.6%
53.8%
0.0%
100%
3.6%
17.5%
44.2%
33.9%
0.8%
100%
The analysis of small business loans reflects excellent penetration throughout the assessment
area. The bank‟s lending levels in each LMI census tract category exceeded both the percentage
of businesses in LMI census tracts and the performance of other lenders. Based on 2009 CRA
aggregate data, 2.5 percent of reported small business loans were made in low-income tracts and
15.8 percent were made in moderate-income tracts.
As noted previously, the bank did not originate any small farm loans in this assessment area
during the review period. Consequently, a geographic distribution analysis of small farm loans
was not completed.
58
Arvest Bank
January 10, 2011
Overall, the bank‟s loan distribution by borrower‟s profile is good, based on performance from
both loan categories reviewed. The following table shows the distribution of HMDA reported
loans by the income level of the borrower in comparison to family population data.
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
2
2
1
6
1
12
16.7%
16.7%
8.3%
50.0%
8.3%
100%
2
3
3
5
0
13
15.4%
23.1%
23.1%
38.5%
0.0%
100%
0
0
1
0
0
1
0.0%
0.0%
100.0%
0.0%
0.0%
100%
0
0
0
0
2
2
0.0%
0.0%
0.0%
0.0%
100.0%
100%
4
5
5
11
3
28
14.3%
17.9%
17.9%
39.3%
10.7%
100%
18.3%
18.8%
23.6%
39.3%
0.0%
100%
The bank‟s level of lending to LMI borrowers within the assessment area is good. Based on the
above table, the bank‟s level of lending to low-income borrowers (14.3 percent) is lower than the
low-income family population (18.3 percent). However, the bank‟s level of lending is much
higher than the 2009 HMDA aggregate lending level to low-income borrowers (8.0 percent).
Furthermore, the bank‟s HMDA lending to moderate-income borrowers (17.9 percent) is similar
to the percentage of moderate-income borrowers within the assessment area (18.8 percent) and
aggregate lending to moderate-income borrowers (17.7 percent).
59
Arvest Bank
January 10, 2011
amount and business revenue size.
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250 <$1,000
27
13
16
56
29.0%
14.0%
17.2%
60.2%
11
8
18
37
11.8%
8.6%
19.4%
39.8%
38
21
34
93
40.9%
22.6%
36.6%
100%
The bank originated a majority of its small business loans (60.2 percent) to businesses with
revenues of $1 million or less, which is less than the Dun & Bradstreet estimate of small
businesses in the assessment area (87.6 percent) but above the 2009 CRA aggregate lending level
to small businesses (22.4 percent). Therefore, the bank‟s level of lending to small businesses is
adequate.
As noted previously, the bank did not originate any small farm loans in this assessment area
during this review period. Consequently, a borrower‟s profile analysis using small farm loans
was not completed.
Despite being in the Kansas City market for only a portion of the evaluation period, Arvest Bank
made a relatively high level of community development loans. The bank originated two
community development loans totaling $23.5 million within this assessment area. Both loans
were to help build senior living facilities in conjunction with NMTCs.
60
Arvest Bank
January 10, 2011
INVESTMENT TEST
Overall, Arvest Bank‟s performance under the Investment Test is rated low satisfactory for the
Kansas City MSA. The bank made an adequate level of qualified community development
investments and grants, exhibiting adequate responsiveness to credit and community
development needs in the Kansas City MSA Assessment Area. As of this evaluation date, the
bank had a balance of $0.6 million in qualified investments attributable to this assessment area
(all of these investments were made in a previous review period, still outstanding). All of the
bank‟s community development investments in the Kansas City MSA are in MBS that finance
affordable housing. Additionally, Arvest Bank made 17 qualified grants totaling $83,440
throughout the assessment area during this review period. Among the contributions were
significant donations to affordable housing organizations, food banks, and community service
organizations that target children from LMI families.
61
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s Service Test performance in the Kansas City MSA is rated low satisfactory.
Service delivery systems are reasonably accessible to geographies and individuals of different
income levels in the Kansas City MSA Assessment Area, and business hours and services do not
vary in a way that inconveniences LMI geographies and/or LMI individuals. However, Arvest
Bank did not provide any community development services in the Kansas City MSA Assessment
Area.
Arvest Bank operates ten branch facilities within the Kansas City MSA Assessment Area. The
following table illustrates the distribution of these branches by income level of the geography, as
compared to key assessment area demographics:
Dataset
Branches
0
1
3
6
0
0.0%
10.0%
30.0%
60.0%
0.0%
TOTAL
10
100%
Census Tracts
8.9%
26.0%
39.3%
23.4%
2.3%
100%
Household
Population
4.6%
22.1%
47.5%
25.8%
0.0%
100%
As illustrated in the above table, Arvest Bank‟s branches in LMI census tracts represent 10.0
percent of all branches in the Kansas City MSA Assessment Area, which is less than LMI
demographic figures. However, the bank has only recently entered the Kansas City MSA market
through bank acquisition activity. Therefore, based on the performance context relating to the
bank‟s limited opportunity to fully mature a branch distribution strategy, the bank‟s delivery
systems are reasonably accessible to the geographies and individuals of different income levels
in the Kansas City MSA Assessment Area.
As mentioned previously, the Kansas City MSA is a new assessment area for the bank, and all
ten bank branches were added during this review period. Therefore, this performance criterion is
not applicable to the bank‟s evaluation for this review period.
62
Arvest Bank
January 10, 2011
the Kansas City MSA Assessment Area. Most branches have Saturday operating hours and offer
Arvest Bank did not provide any community development services within the Kansas City MSA
Assessment Area during the review period.
63
Arvest Bank
January 10, 2011
ARKANSAS23
CRA RATING FOR ARKANSAS:
SATISFACTORY
High Satisfactory
High Satisfactory
Low Satisfactory
Major factors supporting the institution‟s CRA rating for Arkansas include the following:
Arvest Bank‟s lending levels reflect good responsiveness to the credit needs of its Arkansas
assessment areas.
The bank‟s overall geographic distribution of the loans reflects adequate penetration
throughout the Arkansas assessment areas.
The bank makes a relatively high level of community development loans in Arkansas.
Arvest Bank makes a significant level of qualified community development investments and
grants throughout the Arkansas assessment areas.
different income levels in Arkansas assessment areas; further, changes in branch locations
have not adversely affected the accessibility of delivery systems, particularly to LMI
Arvest Bank personnel provides a limited level of community development services in
Arkansas assessment areas.
23
The bank has branches located in Arkansas that are also part of the Fayetteville-Springdale-Rogers multistate MSA
and the Fort Smith multistate MSA. Consequently, this statewide evaluation is adjusted so as not to reflect
performance in the parts of Arkansas contained within a multistate MSA. Refer to the multistate MSA sections of
this report for the ratings and related evaluations of the institution‟s performance in those areas.
64
Arvest Bank
January 10, 2011
Arvest Bank has three separate assessment areas within the state of Arkansas. The bank‟s
performance within two of these assessment areas was reviewed using full-scope CRA
examination procedures, and scoping considerations applicable to the review of the Arkansas
assessment areas are consistent with the overall CRA examination scope as presented in the
Institution, Scope of Examination section. Arvest Bank‟s ratings in the state of Arkansas are
largely based upon performance in the assessment areas reviewed under full-scope CRA
examination procedures; further, in light of the bank‟s branch structure, loan and deposit activity,
and supervisory history, performance in the two full-scope review assessment areas were given
near equal weighting.
To augment the evaluations of full-scope review assessment areas in Arkansas, one community
contact interview was conducted (and five community contacts, previously completed as part of
separate supervisory events, were referenced) in order to ascertain specific community credit
needs, community development opportunities, and local market conditions.24 The community
contact completed as part of this review was with an economic development specialist in
nonMSA Arkansas.
DESCRIPTION OF INSTITUTION’S OPERATIONS IN ARKANSAS
The bank operates 48 branches (20.1 percent of total branches) throughout the three CRA
assessment areas in the state of Arkansas. The following table gives additional detail regarding
the bank‟s operations within Arkansas.
Assessment Area
Offices #
Deposits25
($000s)
Offices %
Deposits %
CRA Review
Procedures
Little Rock MSA
24
50.0%
$781,555
57.1%
Full Scope
NonMSA Arkansas
21
43.8%
$517,836
37.8%
Full Scope
3
6.3%
$69,280
5.1%
Limited Scope
48
100%
$1,368,671
100%
N/A
Hot Springs MSA
STATE TOTAL
As displayed in the table above, the bank‟s deposits in Arkansas total $1.4 billion, which equates
to 14.8 percent of total bank deposits. Further, the vast majority of these Arkansas deposits and
branch resources are attributable to the full-scope review assessment areas.
24
sections, as applicable to the Arkansas assessment areas in which the community contacts were made.
25
Source: Federal Deposit Insurance Corporation “Deposit Market Share Report” as of June 30, 2010
65
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN ARKANSAS
LENDING TEST
Arvest Bank‟s Lending Test performance in the state of Arkansas is rated high satisfactory.
Lending levels reflect good responsiveness to Arkansas assessment area credit needs. The
bank‟s overall geographic distribution of loans reflects adequate penetration throughout
Arkansas assessment areas. Further, the overall distribution of loans by borrower‟s
income/revenue profile reflects excellent penetration among customers of different income levels
and businesses/farms of different sizes. Finally, Arvest Bank makes a relatively high level of
community development loans within Arkansas assessment areas.
Lending Activity
The bank‟s lending levels in the state of Arkansas reflect good responsiveness to assessment area
credit needs, based upon the lending activity analyzed under the Lending Test. This lending
Loan Type
%
$(000s)
%
1,144
49.8%
40,252
31.4%
155
6.7%
14,544
11.3%
22
1.0%
18,646
14.5%
978
42.5%
54,880
42.8%
Total HMDA related
2,299
39.8%
128,322
28.0%
Small Business
2,793
48.3%
294,086
64.1%
687
11.9%
36,538
8.0%
5,779
100%
$458,946
100%
Home Improvement
Home Purchase
Refinancing
Small Farm
TOTAL LOANS
#
66
Arvest Bank
January 10, 2011
As displayed in the following tables, the bank‟s overall geographic distribution of loans reflects
adequate penetration throughout the bank‟s Arkansas assessment areas.
Assessment Area (full-scope review)
Little Rock MSA
Good
Arkansas NonMSA
Adequate
Assessment Area (limited-scope review)
Hot Springs MSA
Consistent
Performance in the Little Rock MSA and nonMSA Arkansas assessment areas were given
similar weight in developing overall conclusions. However, in light of marginally adequate
performance in the Arkansas nonMSA Assessment Area, and the fact that the majority of loans
in this analysis are attributable to the Arkansas nonMSA Assessment Area, the bank‟s overall
geographic distribution of loans performance is adequate.
Arvest Bank‟s overall loan distribution by borrower‟s profile reflects excellent performance in
Arkansas assessment areas, as displayed in the following tables.
Little Rock MSA
Excellent
Arkansas NonMSA
Excellent
Hot Springs MSA
Consistent
67
Arvest Bank
January 10, 2011
Arvest Bank makes a relatively high level of community development loans within the state of
Arkansas. The following table displays community development lending performance in the
bank‟s three Arkansas assessment areas.
Little Rock MSA
Leader
Arkansas NonMSA
Low Level
Hot Springs MSA
Below
Arvest Bank‟s performance in the Little Rock MSA and nonMSA Arkansas assessments areas
was weighted nearly equally in order to develop overall conclusions. However, in light of the
particularly strong community development loan performance in the Little Rock MSA
Assessment Area, paired with the increased significance and opportunity for community
development loan activity in the Little Rock MSA Assessment Area, the bank‟s overall level of
community development lending in the state of Arkansas is relatively high. The bank made four
community development loans totaling $22.6 million in Arkansas assessment areas (three of
these four loans are attributable to the Little Rock MSA Assessment Area).
68
Arvest Bank
January 10, 2011
INVESTMENT TEST
For the state of Arkansas, Arvest Bank‟s performance under the Investment Test is rated high
satisfactory. The following tables display investment and grant activity performance for the
Arkansas assessment areas.
Little Rock MSA
Significant
Arkansas NonMSA
Adequate
Hot Springs MSA
Below
Arvest Bank‟s performance in the Little Rock MSA and nonMSA Arkansas assessments areas
was weighted nearly equally in order to develop overall conclusions. However, in light of the
increased significance and opportunity for community development investment activity in the
Little Rock MSA Assessment Area, the bank‟s overall level of community development
investment/grant activity in the state of Arkansas is significant. Community development
investments in Arkansas assessment areas totaled $4.8 million, all of which were made in MBS
($2.4 million in new investments and $2.4 million in previous review period investments still
outstanding). The bank also made community development grants totaling $404,427 in Arkansas
Assessment areas.
69
Arvest Bank
January 10, 2011
SERVICE TEST
Overall, Arvest Bank‟s performance in Arkansas is rated low satisfactory under the Service Test.
The bank‟s delivery systems are reasonably accessible to geographies and individuals of
different income levels in Arkansas assessment areas. In addition, the bank‟s record of opening
and closing branches has not adversely affected the accessibility of its delivery systems,
particularly to LMI geographies and/or LMI individuals. Business hours and services in
Arkansas do not vary in a way that inconveniences portions of Arkansas assessment areas,
particularly LMI geographies and/or LMI individuals. Lastly, Arvest Bank provides a limited
level of community development services within its Arkansas assessment areas.
As displayed in the following tables, the bank‟s delivery systems in Arkansas assessment areas
are reasonably accessible to geographies and individuals of different income levels.
Little Rock MSA
Arkansas NonMSA
Hot Springs MSA
Consistent
70
Arvest Bank
January 10, 2011
Arvest Bank‟s record of opening and closing branches in its three Arkansas assessment areas has
and/or LMI individuals. The bank‟s performance under this Service Test criterion is displayed
by Arkansas assessment areas in the following tables.
Little Rock MSA
Arkansas NonMSA
Hot Springs MSA
Consistent
Overall, banking services and business hours do not vary in a way that inconveniences certain
portions of the bank‟s Arkansas assessment areas, particularly LMI geographies and/or LMI
individuals. The bank‟s performance under this Service Test criterion is displayed by Arkansas
assessment area in the following tables.
Reasonableness of Business Hours and
Services
Do Not Vary / Inconvenience
Little Rock MSA
Arkansas NonMSA
Services
Consistent
Hot Springs MSA
71
Arvest Bank
January 10, 2011
Arvest Bank provides a limited level of community development services across its Arkansas
assessment areas. The bank‟s performance under this Service Test criterion is displayed by
Arkansas assessment area in the following tables.
Little Rock MSA
Limited Level
Arkansas NonMSA
Adequate Level
Hot Springs MSA
Below
Arvest Bank performance in the Little Rock MSA and nonMSA Arkansas assessments areas was
weighted nearly equally in order to develop overall conclusions. However, in light of the
increased significance and opportunity for community development service activity in the Little
Rock MSA Assessment Area, the bank‟s overall level of community development services in the
state of Arkansas is limited.
72
Arvest Bank
January 10, 2011
LITTLE ROCK-NORTH LITTLE ROCK-CONWAY,
ARKANSAS MSA
(Full-Scope Review)
DESCRIPTION OF INSTITUTION’S OPERATIONS IN LITTLE ROCK-NORTH
LITTLE ROCK-CONWAY, ARKANSAS MSA
Bank Structure
The bank has designated the entire Little Rock-North Little Rock-Conway, Arkansas MSA
(Little Rock MSA) as an assessment area, within which the bank operates 24 of its 239 branches
(10.0 percent). Of the 24 branches, one is located in a low-income census tract, three are in
moderate-income census tracts, 13 are in middle-income census tracts, and seven are located in
upper-income census tracts. During this review period, the bank opened two branches and did
not close any facilities in this assessment. Based on this branch network and other service
delivery systems, the bank is adequately positioned to deliver financial services to substantially
all of the Little Rock MSA Assessment Area.
This assessment area is a competitive banking market, with a total of 37 FDIC-insured
institutions operating within the MSA, based on the FDIC Deposit Market Share Report as of
June 30, 2010. Of those 37 financial institutions, the bank is ranked 7th with a deposit market
share of 5.8 percent. The deposits held at branches throughout the Little Rock MSA represent
8.4 percent of all Arvest Bank deposits.
The Little Rock MSA is a six-county area in central Arkansas anchored by the state‟s capitol and
largest city, Little Rock. The six counties comprising the MSA are Faulkner, Grant, Lonoke,
Perry, Pulaski, and Saline. Based on 2000 census data, the assessment area had a total
population of 610,518. The majority of the population lives in Pulaski County (361,474). The
remaining counties range in population from 10,209 to 86,014. According to U.S. Census
Bureau estimates as of July 2009, the population in the Little Rock MSA has grown to 685,488.
This marks a total population increase of approximately 12.3 percent since the 2000 census.
programs and community development related to affordable rental housing. Further, as the Little
Rock MSA is an environment with significant need, coupled with a strong source of community
development intermediaries (such as nonprofit agencies, higher education institutions, and
government assistance entities), there is a high level of community development opportunity
available for financial institution participation.
73
Arvest Bank
January 10, 2011
The MSA consists of 147 geographies. Based on the 2000 census, the median family income for
the Little Rock MSA was $46,411, which was greater than the state of Arkansas at $38,663. As
of 2009, the HUD estimated median family income for the Little Rock MSA was $60,700. The
following table summarizes the distribution of geographies by income level and the family
population of those census tracts within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
7
34
78
28
0
147
4.8%
23.1%
53.1%
19.0%
0.0%
100%
3,789
30,200
89,974
42,429
0
166,392
2.3%
18.1%
54.1%
25.5%
0.0%
100%
as the income distribution of all Arkansas families.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
32,824
30,091
37,372
66,105
166,392
19.7%
18.1%
22.5%
39.7%
100%
148,233
131,570
163,567
292,693
736,063
20.1%
17.9%
22.2%
39.8%
100%
Arkansas
While income levels in the assessment area are relatively higher than income levels for the state
of Arkansas overall, higher housing costs in the Little Rock MSA keep overall housing
affordability in the assessment area on par with that of the state. The Little Rock MSA
Assessment Area housing affordability ratio (47.0 percent) was the same as the state of Arkansas
figure. Of the six MSA counties, buying a home is most affordable in Grant County (61.0
percent) and least affordable in Pulaski County (46.0 percent). The median housing value in the
assessment area was $80,792, which is much higher than the state of Arkansas at $67,400.
Median monthly gross rent in the Little Rock MSA is also higher ($528) than the state of
Arkansas ($453).
74
Arvest Bank
January 10, 2011
agricultural entities operating within the Little Rock MSA. The following table depicts
employment levels by industry, comparing the Little Rock MSA economy to the state of
Arkansas using the “Location Quotient”26 measure.
Little Rock MSA - Employment by Industry
Industry
2,428
14,351
22,241
61,849
ND
18,459
39,059
47,866
29,331
ND
1.0%
5.7%
8.8%
24.5%
ND
7.3%
15.5%
19.0%
11.6%
ND
LQ Arkansas
0.43
1.02
0.50
0.98
ND
1.38
1.27
1.11
1.08
ND
252,443
100%
N/A
Employment
Construction
Manufacturing
Information
Other Services
TOTAL
% of Total
As displayed in the previous table, the largest industries in the Little Rock MSA are trade,
transportation, and utilities; education and health services; and professional and business
services. The industry mix is similar to the state of Arkansas, with a greater reliance on financial
activities and less reliance on natural resources and mining.
The recent annual average unemployment rates for the Little Rock MSA (4.5 percent in 2008 and
6.2 percent in 2009) were lower than rates for the state of Arkansas (5.3 percent in 2008 and 7.4
percent in 2009).27 Similar to the state of Arkansas, the unemployment level in the Little Rock
MSA continued to rise in 2010 and was projected to be at 7.4 percent in January 2011, an
increase of 1.2 percent from the 2009 annual average; the state of Arkansas was projected to
have an unemployment rate of 8.7 percent in January 2011.
26
27
75
Arvest Bank
January 10, 2011
Community contacts indicated that the Little Rock MSA has a low cost of living with generally
affordable housing. Furthermore, the Little Rock MSA has the highest per capita income in the
state of Arkansas. However, community contacts stressed the need for more affordable rental
housing.
Additionally, contacts noted that banks in the Little Rock area provide stability with their
willingness to lend and involvement in their respective communities. Still, more progress is
needed, which has been hampered by the sluggish economy and the related elimination of most
federally-subsidized loan products geared towards low-income individuals. Consequently,
assistance is needed from local financial institutions to fill the void left by the reduction of
federal government subsidies.
76
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN LITTLE ROCKNORTH LITTLE ROCK-CONWAY, ARKANSAS MSA
LENDING TEST
Lending levels reflect adequate responsiveness to the Little Rock MSA Assessment Area credit
needs. The bank‟s overall geographic distribution of loans reflects good penetration throughout
the assessment area. Further, the overall distribution of loans by borrower‟s income/revenue
profile reflects excellent penetration among customers of different income levels and
businesses/farms of different sizes. Lastly under the Lending Test, Arvest Bank is a leader in
making community development loans within the Little Rock MSA Assessment Area.
Lending Activity
The bank‟s lending levels within the Little Rock MSA reflect adequate responsiveness to
assessment area credit needs based upon the lending activity analyzed under the Lending Test.
This lending activity is displayed by loan type in the following table.
Loan Type
Home Improvement
Home Purchase
Refinancing
Total HMDA related
Small Business
Small Farm
TOTAL LOANS
#
%
$(000s)
%
659
31.8%
$24,141
11.9%
69
3.3%
$7,234
3.6%
4
0.2%
$8,921
4.4%
384
18.5%
$21,132
10.4%
1,116
53.8%
$61,428
30.3%
931
44.9%
$138,377
68.2%
26
1.3%
$3,047
1.5%
2,073
100%
$202,852
100%
77
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Little Rock MSA section, this
assessment area includes seven low-income census tracts and 34 moderate-income census tracts,
from all three loan categories reviewed, the bank‟s geographic distribution of loans reflects good
penetration throughout this assessment area, including the 41 LMI census tracts. The following
table displays the geographic distribution of HMDA loans in comparison to owner-occupied
housing demographics for the assessment area.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
3
28
262
213
0
506
0.6%
5.5%
51.8%
42.1%
0.0%
100%
6
43
427
302
0
778
0.8%
5.5%
54.9%
38.8%
0.0%
100%
1
26
131
90
0
248
0.4%
10.5%
52.8%
36.3%
0.0%
100%
1
1
2
0
0
4
25.0%
25.0%
50.0%
0.0%
0.0%
100%
11
98
822
605
0
1,536
0.7%
6.4%
53.5%
39.4%
0.0%
100%
1.5%
15.0%
55.4%
28.2%
0.0%
100%
Multi-Family
TOTAL
LOANS
Owner Occupied
Housing
Based on the information in the preceding table, the bank‟s lending performance in low-income
geographies is adequate. Total HMDA lending in low-income census tracts (0.7 percent) is
lower than the owner-occupied housing percentage (1.5 percent) but slightly above the 2009
HMDA aggregate lending percentage in low-income census tracts (0.6 percent). Bank lending in
moderate-income census tracts is also adequate. While the bank‟s lending in moderate-income
tracts (6.4 percent) is below the owner-occupied percentage (15.0 percent), it is slightly above
the 2009 HMDA aggregate performance in moderate-income census tracts (6.2 percent).
Therefore, the bank‟s overall geographic distribution of HMDA loans is adequate.
78
Arvest Bank
January 10, 2011
Dataset
Small Business
Loans
Business
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
45
89
238
205
0
577
7.8%
15.4%
41.2%
35.5%
0.0%
100%
5.3%
17.5%
51.3%
26.0%
0.0%
100%
The bank‟s percentage of small business loans in low-income census tracts (7.8 percent) reflects
excellent performance, as it is greater than both the estimated percentage of businesses within
low-income census tracts (5.3 percent) and the 2009 CRA aggregate lending percentage (4.6
percent). The bank‟s performance in moderate-income tracts is considered good. Lending in
moderate-income tracts (15.4 percent) is substantially similar to both the estimated percentage of
businesses located in moderate-income census tracts (17.5 percent) and the CRA aggregate
lending percentage in moderate-income census tracts (15.9 percent). Therefore, the bank‟s
overall geographic distribution of small business loans reflects excellent penetration throughout
the assessment area.
79
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
12
2
2
0
16
0.0%
75.0%
12.5%
12.5%
0.0%
100%
1.2%
17.7%
62.8%
18.2%
0.0%
100%
this assessment area. However, based on the limited loan activity available for review, the
geographic distribution of small farm loans is good. While the bank did not make any small
farm loans in low-income tracts, this is not considered poor performance in light of very small
percentage of farms located in low-income census tracts (1.2 percent). Furthermore, the 2009
CRA aggregate levels in low-income census tracts (1.0 percent) is even smaller. The bank‟s
percentage of small farm loans in moderate-income census tracts (75.0 percent) reflects excellent
performance, as it is significantly higher than both the estimated percentage of farms with in
moderate-income geographies (17.7 percent) and the CRA aggregate lending percentage in
moderate-income census tracts (12.9 percent).
80
Arvest Bank
January 10, 2011
loans by the income level of the borrower in comparison to family population demographics.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
64
143
148
142
9
506
12.6%
28.3%
29.2%
28.1%
1.8%
100%
45
168
184
364
17
778
5.8%
21.6%
23.7%
46.8%
2.2%
100%
24
45
63
112
4
248
9.7%
18.1%
25.4%
45.2%
1.6%
100%
0
0
0
0
4
4
0.0%
0.0%
0.0%
0.0%
100.0%
100%
133
356
395
618
34
1,536
8.7%
23.2%
25.7%
40.2%
2.2%
100%
19.7%
18.1%
22.5%
39.7%
0.0%
100%
Multi-Family
TOTAL
LOANS
Families
As indicated in the preceding table, the bank‟s level of lending to low-income borrowers (8.7
percent) is lower than the low-income family population percentage (19.7 percent). However,
the bank‟s level of lending is higher than the aggregate lending level to low-income borrowers
(7.2 percent), reflecting good performance. Furthermore, the bank‟s lending level to moderateincome borrowers (23.2 percent) is excellent, as it is higher than both the percentage of
moderate-income borrowers within the assessment area (18.1 percent) and the aggregate lending
level to moderate-income borrowers (17.7 percent). Accordingly, the bank‟s overall level of
lending to LMI borrowers is excellent.
81
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250 <$1,000
390
76
55
521
68.1%
13.3%
9.6%
90.9%
18
14
20
52
3.1%
2.4%
3.5%
9.1%
408
90
75
573
71.2%
15.7%
13.1%
100%
with gross annual revenues of $1 million or less. The highest concentration of these loans is for
loan amounts of $100,000 or less, which further demonstrates the bank‟s willingness to make
credit available to small businesses in the assessment area. According to Dun & Bradstreet
estimates, 89.0 percent of assessment area businesses had revenues of $1 million or less. In
addition, the bank‟s level of lending to small businesses surpasses the 2009 CRA aggregate
lending level of 21.9 percent. Based on this information, the bank‟s level of lending to small
businesses is excellent.
28
This analysis included 577 small business loans; however, four of these loans were removed from the sample
82
Arvest Bank
January 10, 2011
Small farm lending performance was analyzed to determine the bank‟s lending levels to farms of
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
12
2
2
16
75.0%
12.5%
12.5%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
12
2
2
16
75.0%
12.5%
12.5%
100%
As displayed in the preceding table, the bank had a relatively low level of small farm loan
activity in this assessment area. However, based on the limited loan activity available for
review, the distribution of small farm loans by borrower‟s profile is excellent. All of the bank‟s
small farm loans were made to farmers with revenues of $1 million dollars or less. Additionally,
the strong majority of these loans were in amounts of $100,000 or less, which further
demonstrates the bank‟s willingness to make credit available to small farms. According to 2009
Dun & Bradstreet estimates, 96.5 percent of farms in the assessment area reported revenues of $1
million or less. Furthermore, the bank‟s small farm lending performance is significantly higher
than the 2009 CRA aggregate level of lending to small farms, 72.3 percent.
Arvest Bank continues to be a leader in making community development loans in the Little Rock
MSA assessment area. The bank originated or renewed three community development loans
totaling $22.5 million within this assessment area since the previous evaluation. Two of the
loans financed construction or renovation projects providing affordable housing to LMI
individuals. The remaining loan was for a project to revitalize a low-income census tract.
83
Arvest Bank
January 10, 2011
INVESTMENT TEST
The bank made a significant level of qualified community development investments and grants,
exhibiting good responsiveness to credit and community development needs in the Little Rock
MSA Assessment Area. As of this evaluation date, the bank had a balance of $3.8 million in
qualified investments attributable to this assessment area, which represents a decrease of $1.1
million (22.4 percent) since the last CRA evaluation. All of the bank‟s qualified investments are
in MBS that finance affordable housing ($2.4 million in new investments and $1.4 million in
previous review period investments still outstanding). Additionally, Arvest Bank made a
significant level of community development grants within the Little Rock MSA. The bank made
76 grants and donations totaling $190,061 during this review period. Among these numerous
grants were significant donations to affordable housing organizations, food banks, and
community service organizations that target children from LMI families.
84
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s service delivery systems are reasonably accessible to the geographies and
individuals of different income levels in this assessment area. The bank‟s record of opening and
closing branches has not adversely affected the accessibility of its delivery systems, particularly
to LMI geographies and/or LMI individuals. Business hours and retail services do not vary in a
way that inconveniences LMI geographies and/or individuals. Finally under the Service Test,
Arvest Bank personnel provides a limited level of community development services within this
assessment area.
Arvest Bank operates 24 branch facilities within the Little Rock MSA Assessment Area. The
following table illustrates the distribution of these facilities by income level of geography, as
Dataset
Branches
1
3
13
7
0
4.2%
12.5%
54.2%
29.2%
0.0%
TOTAL
24
100%
Census Tracts
4.8%
23.1%
53.1%
19.0%
0.0%
100%
Household
Population
2.9%
18.6%
53.2%
25.2%
0.0%
100%
As illustrated in the above table, Arvest Bank‟s branches in LMI census tracts represent 16.7
percent of all branches in the Little Rock MSA Assessment Area. The dispersion of service
delivery systems in low-income census tracts (4.2 percent) is comparable to the percentage of
low-income census tracts (4.8 percent) and greater than the household population percentages in
these tracts (2.9 percent). While, the dispersion of branches in moderate-income tracts (12.5
percent) is less than the percentage of moderate-income geographies (23.1 percent) and
households (18.6 percent), branch dispersion in moderate-income areas is still reasonable.
Therefore, overall service delivery systems are reasonably accessible to geographies and
individuals of different income levels in the assessment area.
The bank‟s record of opening and closing branches has not adversely affected the accessibility of
its delivery systems, particularly in LMI geographies and/or to LMI individuals. During the
review period, the bank opened two branches in the Little Rock MSA. One branch was opened
in a middle-income census tract, and one was opened in an upper-income census tract.
85
Arvest Bank
January 10, 2011
the Little Rock MSA Assessment Area. Most branches have Saturday operating hours and offer
Arvest Bank staff members provided a limited level of community development services within
the Little Rock MSA Assessment Area. One bank employee provided financial expertise to a
community service organization assisting the homeless in the Little Rock area.
86
Arvest Bank
January 10, 2011
HOT SPRINGS, ARKANSAS MSA
(Limited-Scope Review)
DESCRIPTION OF INSTITUTION’S OPERATIONS IN HOT SPRINGS, ARKANSAS
MSA
This assessment area includes the entire Hot Springs, Arkansas MSA, which is comprised of
Garland County. Arvest Bank operates three branch offices in this assessment area. The tables
below detail key demographics relating to this assessment area.
Dataset
Census Tracts
Family
Population
Household
Population
Business
Institutions
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
0
6
11
2
0
19
0.0%
31.6%
57.9%
10.5%
0.0%
100%
0
4,475
17,456
3,465
0
25,396
0.0%
17.6%
68.7%
13.6%
0.0%
100%
0
8,415
24,565
4,816
0
37,796
0.0%
22.3%
65.0%
12.7%
0.0%
100%
0
1,342
2,911
620
0
4,873
0.0%
27.5%
59.7%
12.7%
0.0%
100%
0
5
51
4
0
60
0.0%
8.3%
85.0%
6.7%
0.0%
100%
Assessment Area Demographics by Population Income Level
Demographic Type
Family Population
Household Population
Population Income Classification
Low4,830
19.0%
8,444
22.3%
Moderate4,587
18.1%
6,545
17.3%
87
Middle5,857
23.1%
7,382
19.5%
Upper10,122
39.9%
15,425
40.8%
TOTAL
25,396
100%
37,796
100%
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN HOT SPRINGS,
ARKANSAS MSA
LENDING TEST
Arvest Bank‟s overall lending performance in this assessment area is consistent with Lending
Test performance for the state of Arkansas, as displayed in the following table. For more
detailed information relating to the bank‟s Lending Test performance in this assessment area, see
the tables contained in Appendix C.
Lending Test Criteria
Performance
Lending Activity
Exceeds
Consistent
Distribution of Loans by Borrower‟s Profile
Below
Below
OVERALL
CONSISTENT
While the bank‟s performance under the borrower‟s profile criterion is below overall state
performance, it is still adequate (the overall state of Arkansas distribution of loans by borrower‟s
profile is excellent). However, the bank did not make any community development loans in this
assessment area, reflecting less than adequate performance.
INVESTMENT TEST
Arvest Bank‟s community development investment and grant levels in the Hot Springs MSA
Assessment Area are below overall Investment Test performance for the state of Arkansas.
Arvest Bank did not make any new community development investments during the review
period. However, the bank had investments made in a previous review period, still outstanding
of $119,749 attributable to this assessment area; during the review period, the bank made 12
grants totaling $8,545.
88
Arvest Bank
January 10, 2011
SERVICE TEST
The bank‟s Service Test performance in this assessment area is consistent with the bank‟s overall
Service Test performance in the state of Arkansas, as detailed in the following table.
Service Test Criteria
Performance
Consistent
Consistent
Reasonableness of Business Hours and Services
Consistent
Below
OVERALL
CONSISTENT
89
Arvest Bank
January 10, 2011
NONMETROPOLITAN ARKANSAS STATEWIDE AREA
(Full-Scope Review)
DESCRIPTION OF INSTITUTION’S OPERATIONS IN NONMETROPOLITAN
ARKANSAS
Bank Structure
Arvest Bank has one assessment area within nonMSA Arkansas, where it operates 21 of its 239
branches (8.8 percent). Of the 21 branches, 19 are in middle-income census tracts, and two are
located in upper-income census tracts. During this review period, the bank opened one office in
a middle-income census tract; no branches were closed. Based on this branch network and other
service delivery systems, the bank is largely able to serve the primary areas of central-west
Arkansas and the far north portion of the assessment area (near the Arkansas-Missouri border),
with secondary accessibility to the far eastern portion of the assessment area and the northcentral section of Arkansas.
Based on the FDIC Deposit Market Share Report as of June 30, 2010, 50 FDIC-insured
institutions operated at least one office within this assessment area, and the bank had the fourth
highest deposit market share percentage (5.9 percent). The deposits held at branches throughout
the nonMSA Arkansas Assessment Area represent 5.6 percent of all Arvest Bank deposits.
The nonMSA Arkansas Assessment Area is a 22-county area that covers the central-west and
north-central portions of Arkansas, including the counties of Baxter, Boone, Carroll, Cleburne,
Conway, Fulton, Hot Spring, Izard, Johnson, Logan, Marion, Montgomery, Newton, Polk, Pope,
Prairie, Scott, Searcy, Stone, Van Buren, White, and Yell. There are only two cities in this
assessment area with populations over 20,000 according to U.S. Census Bureau estimates as of
July 2009 (Russellville in Pope County with a population of 27,588 and Searcy in White County
with a population of 23,341). Based on 2000 census data, the assessment area had a total
population of 496,066. The county with the largest population is White County (67,165). The
remaining counties range in population from 8,261 to 54,469. According to U.S. Census Bureau
estimates as of July 2009, the population in the nonMSA Arkansas assessment area has grown to
526,220. This marks a total population increase of approximately 6.1 percent since the 2000
census.
As the demographics of this assessment area cover an expansive part of rural Arkansas, credit
needs in the area are also varied, including a standard blend of consumer and business/farm
credit products. Other particular credit needs in the assessment area (as noted primarily during
community contact interviews) include increased access to credit for businesses (particularly, as
related to business expansion), flexible personal debt consolidation products, and financial
education programs. Further, many parts of this assessment area are sparsely populated, and,
while there is a significant need for community development involvement, oftentimes these rural
areas lack community development resources from which to draw. Of the 99 middle-income
census tracts in this assessment area, 24 were categorized as “underserved” and 20 were
90
Arvest Bank
January 10, 2011
“distressed” in 2009—12 of these census tracts were both underserved and distressed.29
The assessment area consists of 112 geographies. Based on 2000 census data, the median family
income for the assessment area was $34,817, which is slightly higher than the nonMSA Arkansas
figure, $34,263. As of 2009, the HUD estimated median family income for nonMSA Arkansas
was $43,500. The following table summarizes the distribution of geographies by income level
and the family population of those census tracts within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
0
3
99
10
0
112
0.0%
2.7%
88.4%
8.9%
0.0%
100%
0
3,055
124,576
15,306
0
142,937
0.0%
2.1%
87.2%
10.7%
0.0%
100%
as the distribution of families for the state of Arkansas overall.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
25,869
26,749
32,952
57,367
142,937
18.1%
18.7%
23.1%
40.1%
100%
148,233
131,570
163,567
292,693
736,063
20.1%
17.9%
22.2%
39.8%
100%
Arkansas
29
See the glossary in Appendix E for additional detail regarding the categories “underserved” and “distressed”
under the definition of community development.
91
Arvest Bank
January 10, 2011
The nonMSA Arkansas Assessment Area had a housing affordability ratio of 45.0 percent as of
the 2000 census, which indicates that housing in the assessment area was slightly less affordable
than the state of Arkansas (47.0 percent) and significantly less affordable than nonMSA
Arkansas overall (50.0 percent). Of the 22 counties in this assessment area, housing was most
affordable in Prairie County (59.0 percent), while Carroll County had the lowest affordability
ratio (34.0 percent). The median housing value in the assessment area was $64,114, which is
lower than the state of Arkansas ($67,400) but higher than nonMSA Arkansas ($55,810). The
median gross monthly rent in the assessment area ($402) is also lower than the state of Arkansas
figure ($453) but higher than the figure for nonMSA Arkansas overall ($389).
agricultural entities operating within the nonMSA Arkansas Assessment Area. Based on this
information, the following table displays the assessment area industry mix.
92
Arvest Bank
January 10, 2011
Industry
Total Businesses
Accommodation and Food Services
Admn., Support, Waste and Rem. Svc.
Agric., Forestry, Fishing and Hunting
Arts, Entertainment, and Recreation
Construction
Educational Services
Finance and Insurance
Health Care and Social Assistance
Information
Manufacturing
Mgmt. of Comp. and Enterprises
Mining
Other Services (except Public Admn)
Prof., Scientific, and Tech. Svc.
Public Administration
Real Estate and Rental and Leasing
Retail Trade
Transportation
Utilities
Wholesale Trade
TOTAL
% of Total
1,319
5,963
1,253
386
2,338
316
611
1,433
341
1,002
28
50
3,339
1,606
321
951
3,352
736
87
958
5.0%
22.6%
4.7%
1.5%
8.9%
1.2%
2.3%
5.4%
1.3%
3.8%
0.1%
0.2%
12.7%
6.1%
1.2%
3.6%
12.7%
2.8%
0.3%
3.6%
26,390
100%
As displayed in the previous table, the largest industries in the assessment area are
administrative, support, waste and removal services; retail trade; and other services. The annual
unemployment rates in the assessment area varied significantly by county.30 The lowest 2008
average annual unemployment rate was 4.3 percent (Carroll and Yell counties), and the highest
unemployment rate was 6.4 percent (Izard County). In 2009, 5.6 percent was the lowest average
annual unemployment rate (Carroll County), and the highest unemployment rate was 11.1
percent (Marion County). In comparison, the average annual unemployment rates for the state of
Arkansas were 5.3 percent in 2008 and 7.4 percent in 2009.
30
93
Arvest Bank
January 10, 2011
According to community contacts, overall unemployment in nonMSA Arkansas has remained
relatively low compared to national and state averages. Many communities have seen increases
in population, particularly in the Hispanic population. While some nonMSA areas are becoming
too saturated with financial institutions, community contacts stated that credit is tight. The
greatest need in most communities is small business lending, followed by residential real estate
lending.
Arvest Bank was noted as a top performer in various assessment area communities, though the
community contacts stated that there are a number of ways that banks could advance their
involvement. First, local businesses need increased access to credit in order to expand operations.
With the population influx, job retention and creation are of utmost importance. In addition,
there is a need for affordable housing in many areas. This includes rehabbing existing housing
and new construction. Several other community programs seeking financial institution
assistance are affordable loan programs for debt consolidation, home improvement, and home
purchases, particularly for individuals with both flawed credit and no credit. Community
contacts stated that financial education to LMI community members would be helpful as well.
94
Arvest Bank
January 10, 2011
CONCLUSIONS
WITH
RESPECT
NONMETROPOLITAN ARKANSAS
TO
PERFORMANCE
TESTS
IN
LENDING TEST
Lending levels reflect excellent responsiveness to nonMSA Arkansas Assessment Area credit
needs. The bank‟s overall geographic distribution of loans reflects adequate penetration
throughout the assessment area. Further, the overall distribution of loans by borrower‟s
and businesses/farms of different sizes. Lastly, Arvest Bank makes a low level of community
development loans in the nonMSA Arkansas Assessment Area.
Lending Activity
The bank‟s lending levels within the nonMSA Arkansas Assessment Area reflect excellent
responsiveness to assessment area credit needs based upon the lending activity analyzed under
the Lending Test. This lending activity is displayed by loan type in the following table.
Loan Type
%
$(000s)
385
11.3%
$12,965
5.7%
Home Purchase
78
2.3%
$6,288
2.8%
13
0.4%
$2,348
1.0%
571
16.8%
$32,382
14.2%
Total HMDA related
1,047
30.9%
$53,983
23.7%
Small Business
1,685
49.7%
$139,843
61.5%
661
19.5%
$33,491
14.7%
3,393
100%
$227,317
100%
Home Improvement
Refinancing
Small Farm
TOTAL LOANS
#
95
%
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in nonMSA Arkansas section, this
assessment area does not contain any low-income census tracts and only has three moderateincome census tracts (2.7 percent of all assessment area census tracts). Overall, based on lending
activity from all three loan categories reviewed, the geographic distribution of loans reflects
adequate penetration throughout the assessment area. The following table displays the
geographic distribution of HMDA loans in comparison to owner-occupied housing demographics
for the assessment area
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
1
271
68
0
340
0.0%
0.3%
79.7%
20.0%
0.0%
100%
0
2
757
100
0
859
0.0%
0.2%
88.1%
11.6%
0.0%
100%
0
0
110
10
0
120
0.0%
0.0%
91.7%
8.3%
0.0%
100%
0
0
12
0
0
12
0.0%
0.0%
100.0%
0.0%
0.0%
100%
0
3
1,150
178
0
1,331
0.0%
0.2%
86.4%
13.4%
0.0%
100%
0.0%
2.4%
87.4%
10.3%
0.0%
100%
Multi-Family
TOTAL
LOANS
Owner Occupied
Housing
As displayed in the previous table, the bank‟s level of lending in moderate-income census tracts
is below comparison data. However, based on the bank‟s performance context, the geographic
distribution of HMDA loans is adequate. The bank‟s level of lending in moderate-income
census tracts (0.2 percent) is below both the percentage of owner-occupied housing in moderateincome census tracts (2.4 percent) and the 2009 HMDA aggregate lending level in moderateincome census tracts (1.6 percent). However, as noted in the Description of Institution’s
Operations in nonMSA Arkansas section, there are two portions of the bank‟s nonMSA Arkansas
Assessment Area, where the bank‟s accessibility to services is limited—north-central Arkansas
and the far eastern portion of the assessment area. The only three moderate-income census tracts
in this assessment area are within north-central Arkansas (the far eastern section of the
assessment area contains only middle- and upper-income census tracts, where the bank‟s loan
96
Arvest Bank
January 10, 2011
penetration was also sparse). Furthermore, the three moderate-income census tracts in question
are located in three separate counties, Newton, Searcy, and Van Buren. Within these three
counties, there are ten financial institutions operating 21 branch facilities,31 which indicate these
counties are adequately served by financial institutions, and, consequently, Arvest Bank is at a
competitive disadvantage in penetrating these areas. Therefore, in light of performance context
relating to the bank‟s limited service accessibility in north-central Arkansas, the bank‟s
geographic distribution of HMDA loans is adequate.
Dataset
Small Business
Loans
Business
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
3
843
83
0
929
0.0%
0.3%
90.7%
8.9%
0.0%
100%
0.0%
1.7%
87.6%
10.7%
0.0%
100%
is below comparison data. The bank‟s level of lending in moderate-income census tracts (0.3
percent) is below both the percentage of businesses in moderate-income census tracts (1.7
percent) and the 2009 CRA aggregate lending level in moderate-income census tracts (2.2
percent). However, in light of performance context32 relating to the bank‟s limited service
accessibility in north-central Arkansas, the bank‟s geographic distribution of small business
loans is adequate.
31
32
Source: Federal Deposit Insurance Corporation Deposit Market Share Report as of June 30, 2010
See the geographic distribution of HMDA loans analysis in this section, for additional discussion regarding the
bank‟s performance context as it relates to this analysis.
97
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
1
257
37
0
295
0.0%
0.3%
87.1%
12.5%
0.0%
100%
0.0%
1.5%
89.8%
8.8%
0.0%
100%
is below comparison data. The bank‟s level of lending in moderate-income census tracts (0.3
percent) is below both the percentage of businesses in moderate-income census tracts (1.5
percent). However, in light of performance context33 relating to the bank‟s limited service
accessibility in north-central Arkansas, the bank‟s geographic distribution of small farm loans is
adequate.
33
See the geographic distribution of HMDA loans analysis in this section, for additional discussion regarding the
bank‟s performance context as it relates to this analysis.
98
Arvest Bank
January 10, 2011
from all three loan categories reviewed. The following table shows the distribution of HMDAreported loans by the income level of the borrower in comparison to family population
demographics.
Dataset
Home Purchase
Refinance
Home
Improvement
Low-
Moderate-
Middle-
Upper-
Unknown
31
66
102
137
4
9.1%
19.4%
30.0%
40.3%
1.2%
61
132
180
473
13
7.1%
15.4%
21.0%
55.1%
1.5%
27
22
58
22.5%
18.3%
48.3%
0
0
0
8
6.7%
0
5
4.2%
TOTAL
340
100%
859
100%
120
100%
12
12
100%
100%
Multi-Family
TOTAL
LOANS
Families
0.0%
0.0%
0.0%
0.0%
100
225
304
668
34
1,331
7.5%
16.9%
22.8%
50.2%
2.6%
100%
18.1%
18.7%
23.1%
40.1%
0.0%
100%
The bank‟s level of lending to low-income borrowers within the assessment area is good. While
the bank‟s lending level to low-income borrowers (7.5 percent) is lower than the low-income
family population (18.1 percent), it is significantly higher than the 2009 HMDA aggregate
lending level to low-income borrowers (5.2 percent). Similarly, the bank‟s HMDA lending to
moderate-income borrowers (16.9 percent) is only slightly below the percentage of moderateincome families within the assessment area (18.7 percent) and higher than aggregate lending to
moderate-income borrowers (14.9 percent). Therefore, the bank‟s distribution of HMDA loans
among customers of different income levels is good.
99
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
>$100<$250
>$250 <$1,000
743
90
51
884
81.0%
9.8%
5.6%
96.4%
13
10
10
33
1.4%
1.1%
1.1%
3.6%
756
100
61
917
82.4%
10.9%
6.7%
100%
TOTAL
TOTAL
<$100
The bank‟s level of lending to small businesses is excellent. The bank originated a substantial
majority of its small business loans (96.4 percent) to businesses with revenues of $1 million or
less. The highest concentration of these loans was for loan amounts of $100,000 or less, which
further demonstrates the bank‟s willingness to make credit available to small businesses in the
assessment area. According to Dun & Bradstreet estimates, 91.5 percent of businesses reporting
for 2009 had revenues of $1 million or less. In addition, the bank‟s level of lending to small
businesses surpasses the 2009 CRA aggregate lending level of 24.4 percent.
100
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250 >$250<$500
TOTAL
260
25
9
294
88.1%
8.5%
3.1%
99.7%
0
0
1
1
0.0%
0.0%
0.3%
0.3%
260
25
10
295
88.1%
8.5%
3.4%
100%
All but one of the bank‟s small farm loans (99.7 percent) made in this assessment area were
originated to farmers with revenues one of $1 million dollars or less. Additionally, the largest
concentration of these loans was in loan amounts of $100,000 or less, which further demonstrates
the bank‟s willingness to make credit available to small farms in the assessment area. According
to Dun & Bradstreet estimates, 98.9 percent of farms in the assessment area reported revenues of
$1 million or less. The bank‟s small farm lending level is significantly higher than the 2009
CRA aggregate lending level to small farms, 82.5 percent. Therefore, the bank‟s distribution of
small farm loans by borrower‟s revenue profile is excellent.
Arvest Bank makes a low level of community development loans in the nonMSA Arkansas
Assessment Area. The bank originated one community development loan totaling $95,000
within this assessment area since the previous evaluation. This loan was made to assist a school
district serving a large portion of students from LMI families.
101
Arvest Bank
January 10, 2011
INVESTMENT TEST
The bank made an adequate level of qualified community development investments and grants,
exhibiting good responsiveness to credit and community development needs in the nonMSA
Arkansas Assessment Area. As of the evaluation date, the bank had a balance of $0.9 million in
qualified investments attributable to this assessment area, which represents a decrease of $0.4
million (30.8 percent) since the last CRA evaluation. All of the bank‟s qualified investments are
in MBS that finance affordable housing, which were made in a previous review period, still
outstanding. Additionally, Arvest Bank made a significant level of community development
grants within the assessment area. The bank made 134 qualified grants during this review
period, which totaled $205,821. Among these numerous grants were significant donations to
local schools serving a large majority of students from LMI families, affordable housing
organizations, food banks, and community service organizations that target children from LMI
families.
102
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s service delivery systems are reasonably accessible to the geographies and
individuals of different income levels in the nonMSA Arkansas Assessment Area. The bank‟s
record of opening and closing branches has not adversely affected the accessibility of its delivery
systems, particularly to LMI geographies and/or LMI individuals. Business hours and retail
services do not vary in a way that inconveniences LMI geographies and/or LMI individuals.
Finally, Arvest Bank personnel provides an adequate level of community development services
within this assessment area.
Arvest Bank operates 21 branch facilities within the nonMSA Arkansas Assessment Area. The
Dataset
Branches
0
0
19
2
0
0.0%
0.0%
90.5%
9.5%
0.0%
TOTAL
21
100%
Census Tracts
0.0%
2.7%
88.4%
8.9%
0.0%
100%
Household
Population
0.0%
2.2%
87.7%
10.1%
0.0%
100%
While the bank does not operate any branches in moderate-income census tracts within the
nonMSA Arkansas Assessment Area, these moderate-income census tracts represent a very small
part of the overall assessment area. Further, the moderate-income geographies are located an
extended distance from the bank‟s core markets. As displayed in the table above, the substantial
majority of the bank‟s branches are located in middle-income census tracts, which is
commensurate with the overall makeup of the assessment area. Therefore, the bank‟s delivery
systems are reasonably accessible to the geographies and individuals of different income levels
in the assessment area.
The bank‟s record of opening and closing branches has not adversely affected the accessibility of
its delivery systems, particularly to LMI geographies and/or to LMI individuals. During the
review period, the bank opened one branch in this assessment area, which is in a middle-income
census tract.
103
Arvest Bank
January 10, 2011
the nonMSA Arkansas Assessment Area. Most branches have Saturday operating hours and
offer extended hours of operations in their lobby and drive-up facilities at some point during the
week. Most drive-thru facilities remain open until 6 p.m., Monday through Friday, and are open
until noon on Saturdays. All branches offer the same standard products, including low-cost
checking and savings accounts, certificates of deposit, real estate and consumer loans, and other
services. Therefore, bank services do not vary in a way that inconveniences certain segments of
this assessment area, particularly LMI geographies and/or LMI individuals.
Arvest Bank staff members provided an adequate level of community development services
within the nonMSA Arkansas Assessment Area. Three bank employees provided financial
expertise on an ongoing basis to community development organizations. Two employees
assisted affordable housing organizations, and another employee served an organization that
helps low-income students obtain higher education scholarships.
104
Arvest Bank
January 10, 2011
KANSAS34
CRA RATING FOR KANSAS:
SATISFACTORY
High Satisfactory
Needs to Improve
Low Satisfactory
Major factors supporting the institution‟s state of Kansas rating include the following:
Arvest Bank‟s lending levels reflect excellent responsiveness to the credit needs of its Kansas
assessment area.
throughout the Kansas assessment area.
For the second consecutive CRA evaluation period, the bank did not make any community
development loans in the Kansas assessment area.
Arvest Bank makes a poor level of qualified investments and grants in the Kansas assessment
area.
different income levels in the Kansas assessment area; further, the bank‟s record of
opening/closing branches has not adversely affected the accessibility of delivery systems,
particularly to LMI geographies and/or LMI individuals.
For the second consecutive CRA evaluation period, the bank did not provide any community
development services within the Kansas assessment area.
34
The bank has branches located in Kansas that are also part of the Kansas City multistate MSA. Consequently, this
statewide evaluation is adjusted so as not to reflect performance in the parts of Kansas contained within a
multistate MSA. Refer to the multistate MSA section of this report for the rating and related evaluation of the
institution‟s performance in that area.
105
Arvest Bank
January 10, 2011
Arvest Bank has one assessment area within the state of Kansas, which was reviewed using fullscope CRA examination procedures. Consequently, Arvest Bank‟s ratings in the state of Kansas
are based solely on this single assessment area. Scoping considerations applicable to the review
of the Kansas assessment area are consistent with the overall CRA examination scope as
presented in the Institution, Scope of Examination section.
To augment the evaluation of the bank‟s Kansas assessment area, two community contact
interviews were conducted in order to ascertain specific community credit needs, community
development opportunities, and local market conditions.35 Both community contacts specialize
in economic development targeted to the southeast corner of Kansas.
DESCRIPTION OF INSTITUTION’S OPERATIONS IN KANSAS
Bank Structure
Arvest Bank operates one of its 239 branches (0.4 percent) within the nonMSA Kansas
Assessment Area, which is in a middle-income census tract. Based on the bank‟s very limited
branch presence in this assessment area, Arvest Bank is not able to effectively serve all parts of
the assessment area, particularly the two northernmost counties of Bourbon and Crawford.
This assessment area is a competitive banking market, with a total of 35 FDIC-insured
institutions operating within the assessment area, based on the FDIC Deposit Market Share
Report as of June 30, 2010. Of the 35 financial institutions with an office in this assessment
area, the bank ranked 23rd with a deposit market share of 1.2 percent. Based on this information,
Arvest Bank deposits held at branches throughout nonMSA Kansas Assessment Area represent
0.3 percent of the bank‟s total deposits.
The nonMSA Kansas Assessment Area is a six-county area that covers the southeastern corner of
the state of Kansas; it includes the following counties: Bourbon, Chautauqua, Cherokee,
Crawford, Labette, and Montgomery. According to U.S. Census Bureau estimates as of July
2009, the largest city in this assessment area is Pittsburg in Crawford County with a population
of 19,639. Based on 2000 census data, the assessment area had a total population of 139,672.
The county with the largest population is Crawford County (38,242). The remaining counties
range in population from 4,359 to 36,252. According to U.S. Census Bureau estimates as of July
2009, the population in the nonMSA Kansas Assessment Area has decreased to 134,592. This
marks a total population decrease of approximately 3.6 percent since the 2000 census.
35
Operations section.
106
Arvest Bank
January 10, 2011
As the demographics of this assessment area cover an expansive part of rural Kansas, credit
needs in the area are varied and include a mix of consumer and business/farm credit products.
Other particular credit needs in the assessment area (as noted primarily during community
contact interviews) include increased access to credit for businesses (particularly, as related to
storefront operations and microloan programs), revolving home improvement loans, and
participation in tax credit programs. Further, many parts of this assessment area are sparsely
populated, and, while there is significant need for community development involvement,
oftentimes these rural areas lack community development resources from which to draw.36
The assessment area consists of 44 geographies. Based on the 2000 census, the median family
income for the assessment area was $38,562, which was below the nonMSA Kansas figure,
$41,490. As of 2009, the HUD estimated median family income for nonMSA Kansas to be
$52,100. The following table summarizes the distribution of geographies by income level and
the family population of those census tracts within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
0
9
34
1
0
44
20.5%
77.3%
2.3%
5,578
30,539
1,312
14.9%
81.6%
3.5%
0.0%
0
0.0%
0.0%
0
100%
37,429
0.0%
100%
The following table displays the distribution of assessment area families by income level,
compared to the family distribution for nonMSA Kansas.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
7,616
7,781
9,370
12,662
37,429
20.3%
20.8%
25.0%
33.8%
100%
117,432
171,758
130,953
286,643
706,786
16.6%
24.3%
18.5%
40.6%
100%
NonMSA
Kansas
36
Of the 34 middle-income census tracts in this assessment area, one was categorized as “underserved” in 2009.
See the glossary in Appendix E for additional detail regarding the term “underserved” under the definition of
community development.
107
Arvest Bank
January 10, 2011
Housing in the assessment area appears to be very affordable. The nonMSA Kansas Assessment
Area had a housing affordability ratio of 62.0 percent as of the 2000 census, which indicates
greater affordability than nonMSA Kansas overall (58.0 percent). Of the six counties in this
assessment area, housing was most affordable in Chautauqua County (84.0 percent), while
Crawford County (53.0 percent) had the lowest affordability ratio. The remaining four counties
have affordability ratios ranging from 63.0 to 69.0 percent. The median housing value in the
assessment area was $48,609, which is significantly lower than nonMSA Kansas at $57,883.
Median gross monthly rent in the assessment area ($410) was similar to nonMSA Kansas ($405).
agricultural entities operating within the nonMSA Kansas Assessment Area. The following table
depicts the number of businesses by industry in the assessment area.
108
Arvest Bank
January 10, 2011
Total
Businesses
295
1,333
638
92
517
87
200
528
96
300
4
36
1,015
454
73
267
755
175
23
273
Industry
Construction
Information
Manufacturing
Mining
Retail Trade
Transportation
Utilities
Wholesale Trade
TOTAL
7,161
% of Total
4.1%
18.6%
8.9%
1.3%
7.2%
1.2%
2.8%
7.4%
1.3%
4.2%
0.1%
0.5%
14.2%
6.3%
1.0%
3.7%
10.5%
2.4%
0.3%
3.8%
100%
administrative, support, waste and removal services and other services. The average annual
unemployment rates in the assessment area were generally higher than the state of Kansas
overall.37 The lowest 2008 average annual unemployment rate was 4.4 percent (Chautauqua
County), and the highest unemployment rate was 5.4 percent (Montgomery County). In 2009,
6.9 percent was the lowest average annual unemployment rate (Bourbon County), and the
highest unemployment rate was 9.8 percent (Montgomery County). In comparison, the average
annual unemployment rates for the state of Kansas were 4.5 percent in 2008 and 7.1 percent in
2009.
37
U.S. Department of Labor; unemployment rates are not seasonally adjusted.
109
Arvest Bank
January 10, 2011
Community contacts noted that the rural communities in southeast Kansas have experienced an
aging and declining population in recent years. Contacts surmised that some population loss is
due to few opportunities for advanced education. Furthermore, statewide resources are difficult
to attain because of the lack of an interstate highway connecting the communities to a
surrounding MSA. Agricultural lending is a significant credit need in the area, but most large
farmers receive credit through the USDA, and smaller entities are hobby farmers with few
demands for financing. With that in mind, community contact information revealed that small
business lending is the greatest concern in southeast Kansas.
Overall, community contacts noted that banks in the assessment area have been receptive to
community development projects. Banks have participated in affordable housing projects,
microloan programs for small businesses, and redevelopment and recruitment of new businesses
to the area. Other initiatives in which financial institutions could participate include down
payment assistance, low interest rate loan programs for storefront operations, revolving loan
funds for home improvement projects, grant matching loan programs to assist entrepreneurs, and
tax credit programs. According to community contacts, it is vital for more banks in the area to
get involved with these programs to further develop the struggling economy of southeast Kansas.
110
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN KANSAS
LENDING TEST
Arvest Bank‟s Lending Test performance in Kansas is rated high satisfactory. Lending levels
reflect excellent responsiveness to assessment area credit needs. The geographic distribution of
loans reflects adequate penetration throughout the assessment area. The loan distribution by
borrower‟s income/revenue profile reflects excellent penetration among customers of different
income levels and businesses/farms of different sizes. However, for the second consecutive
CRA evaluation, the bank did not make any community development loans in the nonMSA
Kansas Assessment Area.
Lending Activity
The bank‟s lending levels reflect excellent responsiveness to nonMSA Kansas Assessment Area
credit needs, based upon the lending activity analyzed under the Lending Test. This lending
Loan Type
Home Improvement
#
%
$(000s)
%
22
5.5%
$506
2.7%
Home Purchase
4
1.0%
$121
0.6%
0
0.0%
$0
0.0%
25
6.3%
$1,512
8.0%
51
12.8%
$2,139
11.3%
Small Business
201
50.5%
$13,451
71.3%
Small Farm
146
36.7%
$3,272
17.3%
398
100%
$18,862
100%
Refinancing
Total HMDA related
TOTAL LOANS
111
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Kansas section, this assessment area
contains zero low-income census tracts and nine moderate-income census tracts. Overall, based
on lending activity from all three loan categories reviewed, the geographic distribution of loans
reflects adequate penetration throughout the assessment area. The following table displays the
for the assessment area.
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
TOTAL
LOANS
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
16
0
0
0.0%
0
0.0%
100%
0.0%
100%
21
16.0%
84.0%
1
7
12.5%
87.5%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
5
44
0
0
49
0.0%
10.2%
89.8%
0.0%
0.0%
100%
0.0%
13.9%
82.9%
3.2%
0.0%
100%
0
0.0%
0.0%
0
0.0%
0
16
4
0.0%
0
0.0%
TOTAL
0.0%
0
0.0%
25
100%
8
100%
The analysis of the bank‟s 2009 HMDA-lending activity revealed that lending in moderateincome census tracts is good. While the bank did not make any home purchase loans in
moderate-income census tracts, refinance loans (the primary HMDA loan product in this
assessment area) and home improvement loans made in moderate-income census tracts
accounted for 10.2 percent of all HMDA loans, which is below the owner-occupied housing
percentage in moderate-income census tracts, 13.9 percent, but above the 2009 HMDA aggregate
level of loans made in moderate-income census tracts, 10.0 percent.
112
Arvest Bank
January 10, 2011
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
5
103
0
0
0.0%
0.0%
4.6%
95.4%
19.6%
77.2%
0.0%
3.2%
0.0%
0.0%
TOTAL
108
100%
100%
The analysis of small business loans reflects poor penetration throughout the assessment area.
The bank only made 4.6 percent of small business loans in moderate-income census tracts, which
is significantly less than the estimated percentage of businesses within moderate-income census
tracts, 19.6 percent, and the 2009 CRA aggregate level of small business loans made in
moderate-income census tracts, 18.5 percent.
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
2
77
0
0
0.0%
0.0%
2.5%
4.1%
97.5%
94.4%
0.0%
1.4%
0.0%
0.0%
TOTAL
79
100%
100%
While below data used for comparison, the bank‟s geographic distribution of small farm loans is
adequate. As displayed in the preceding table, the bank‟s level of small farm loans made within
moderate-income census tracts (2.5 percent) is below, but within an adequate range of the
estimated percentage of farms located in moderate-income census tracts (4.1 percent). Based on
2009 CRA aggregate data, the level of small farm loans made in moderate-income census tracts
by other lenders (3.9 percent) was also below the estimated percentage of farms in moderateincome census tracts.
113
Arvest Bank
January 10, 2011
reported loans by the income level of the borrower in comparison to family population
demographics.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
2
8
0
6
0
12.5%
50.0%
3
3
4
15
12.0%
12.0%
16.0%
60.0%
1
0
2
4
1
8
25.0%
50.0%
12.5%
100%
12.5%
0.0%
0.0%
37.5%
0.0%
0
0.0%
16
100%
25
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
6
11
6
25
1
49
12.2%
22.4%
12.2%
51.0%
2.0%
100%
20.3%
20.8%
25.0%
33.8%
0.0%
100%
Multi-Family
TOTAL
LOANS
Families
The bank‟s level of lending to LMI borrowers within the assessment area is excellent. Based on
the above table, the bank‟s level of lending to low-income borrowers (12.2 percent) is lower than
the low-income family population (20.3 percent). However, the bank‟s level of lending is higher
than the 2009 HMDA aggregate lending level to low-income borrowers (9.4 percent), reflecting
good overall penetration. Furthermore, the bank‟s HMDA lending to moderate-income
borrowers (22.4 percent) is above the percentage of moderate-income borrowers within the
assessment area (20.8 percent), and it is significantly higher than the aggregate lending level to
moderate-income borrowers (15.6 percent), reflecting excellent overall penetration.
114
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
>100<$250
>$250 <$1,000
92
7
2
101
85.2%
6.5%
1.9%
93.5%
1
1
5
7
0.9%
0.9%
4.6%
6.5%
93
8
7
108
86.1%
7.4%
6.5%
100%
TOTAL
TOTAL
<$100
majority of its business loans (93.5 percent) to businesses with revenues of $1 million or less.
The highest concentration of these loans was for loan amounts of $100,000 or less, which further
demonstrates the bank‟s willingness to make credit available to small businesses in the
for 2009 had gross annual revenues of $1 million or less. In addition, the bank‟s level of lending
to small businesses significantly exceeded the 2009 CRA aggregate lending level of 15.8
percent.
115
Arvest Bank
January 10, 2011
Small farm lending performance was analyzed by the revenue size of the farm and by the dollar
amount of the loan. The following table shows the distribution of small farm loans by loan
amount and farm revenue size.
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
77
2
0
79
97.5%
2.5%
0.0%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
77
2
0
79
97.5%
2.5%
0.0%
100%
All of the bank‟s small farm loans were made to farmers with revenues of $1 million dollars or
less, reflecting excellent performance. Additionally, the largest concentration of these loans was
in loan amounts of $100,000 or less, which further demonstrates the bank‟s willingness to make
credit available to small farms in the assessment area. According to Dun & Bradstreet estimates,
99.5 percent of farms in the assessment area reported revenues of $1 million or less. The bank‟s
farm lending is significantly higher than the 2009 CRA aggregate data lending level to small
farms, 79.9 percent.
Arvest Bank did not make any community development loans in the nonMSA Kansas
Assessment Area during the review period, as was the case at the bank‟s previous CRA
evaluation.
116
Arvest Bank
January 10, 2011
INVESTMENT TEST
Overall, Arvest Bank‟s performance under the Investment Test is rated needs to improve for the
state of Kansas. The bank made a poor level of qualified community development investments
and grants, exhibiting poor responsiveness to credit and community development needs in the
assessment area. During this review period, the bank had $47,229 in qualified investments
attributable to this assessment area, which represents a decrease of $17,572 (27.1 percent) since
the last CRA evaluation. All of the bank‟s qualified investments are in MBS that finance
affordable housing, which were made in a previous review period, still outstanding.
Additionally, Arvest Bank made no qualified community development grants within the
assessment area, as was the case at the bank‟s previous CRA evaluation.
SERVICE TEST
Arvest Bank‟s Service Test rating in the state of Kansas is low satisfactory. The bank‟s service
delivery systems are reasonably accessible to the assessment area, and the bank‟s record of
opening and closing branches has not adversely affected the accessibility of its delivery systems
to LMI geographies and/or LMI individuals. Business hours and services do not vary in a way
that inconveniences LMI geographies and/or LMI individuals. Conversely, for the second
consecutive CRA evaluation, the bank did not provide any community development services in
the nonMSA Kansas Assessment Area.
The bank operates one branch office in this assessment area, which is in a middle-income census
tract. The strong majority of census tracts in this assessment area are designated as middleincome (77.3 percent), and the vast majority of households are within middle-income census
tracts (79.1 percent). Therefore, Arvest Bank‟s delivery systems are reasonably accessible to the
geographies and individuals of different income levels in the nonMSA Kansas Assessment Area.
The bank‟s record of opening and closing branches in the nonMSA Kansas Assessment Area has
and/or to LMI individuals. The bank did not open or close any branches during this review
period.
While the bank only operates one branch in the nonMSA Kansas Assessment Area, its business
hours and banking products and services are consistent with the majority of all other Arvest
Bank offices. Therefore, bank services do not vary in a way that inconveniences certain
segments of this assessment area, particularly LMI geographies and/or LMI individuals.
117
Arvest Bank
January 10, 2011
Arvest Bank did not provide any community development services in the nonMSA Kansas
Assessment Area during the reviewed period, as was the case for the bank‟s previous CRA
evaluation.
118
Arvest Bank
January 10, 2011
MISSOURI38
CRA RATING FOR MISSOURI:
SATISFACTORY
High Satisfactory
Low Satisfactory
Low Satisfactory
Major factors supporting the institution‟s CRA rating for Missouri include the following:
Arvest Bank‟s lending levels reflect excellent responsiveness to the credit needs of its
Missouri assessment areas.
throughout the Missouri assessment areas.
The overall distribution of loans by borrower‟s income/revenue profile reflects excellent
penetration among borrowers of different income levels and businesses/farms of different
sizes.
Arvest Bank makes a low level of community development loans in Missouri.
Arvest Bank makes an adequate level of qualified community development investments and
grants throughout the Missouri assessment areas.
different income levels in Missouri assessment areas; further, changes in branch locations
have not adversely affected the accessibility of delivery systems, particularly to LMI
Arvest Bank personnel provides few, if any, community development services in Missouri
assessment areas.
38
The bank has branches located in Missouri that are also part of the Fayetteville-Springdale-Rogers multistate MSA
and the Kansas City multistate MSA. Consequently, this statewide evaluation is adjusted so as not to reflect
performance in the parts of Missouri contained within a multistate MSA. Refer to the multistate MSA sections of
this report for the ratings and related evaluations of the institution‟s performance in those areas.
119
Arvest Bank
January 10, 2011
Arvest Bank has three separate assessment areas within the state of Missouri, and scoping
considerations applicable to the review of the Missouri assessment areas are consistent with the
overall CRA examination scope as presented in the Institution, Scope of Examination section.
The bank‟s performance within one of these assessment areas was reviewed using full-scope
CRA examination procedures, which formed the primary basis for the bank‟s overall ratings in
the state of Missouri.
To augment the evaluation of the Missouri full-scope review assessment area, two community
contact interviews were conducted in order to ascertain specific community credit needs,
community development opportunities, and local market conditions.39 Both interviews took
place with representatives from the southwest corner of nonMSA Missouri—one interview was
with a business retention/expansion coordinator and one was with a community/business
development specialist.
DESCRIPTION OF INSTITUTION’S OPERATIONS IN MISSOURI
The bank operates 18 branches (7.5 percent of total branches) throughout the three CRA
assessment areas in the state of Missouri. The following table gives additional detail regarding
the bank‟s operations within Missouri.
Assessment Area
NonMSA Missouri
Joplin MSA
Springfield MSA
STATE TOTAL
Offices %
Deposits40
($000s)
Deposits %
CRA Review
Procedures
4
22.2%
$58,841
14.6%
Full Scope
10
55.6%
$329,726
81.6%
Limited Scope
4
22.2%
$15,397
3.8%
Limited Scope
18
100%
$403,964
100%
N/A
Offices #
Deposits attributable to 18 Missouri branches total $404.0 million, which equates to 4.4 percent
of total bank deposits.
39
section, as applicable to the Missouri full-scope review assessment area in which the community contacts were
made.
40
120
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN MISSOURI
LENDING TEST
Arvest Bank‟s Lending Test performance in the state of Missouri is rated high satisfactory.
Lending levels reflect excellent responsiveness to the credit needs in Missouri assessment areas.
The bank‟s overall geographic distribution of loans reflects adequate penetration throughout
Missouri assessment areas. Further, the overall distribution of loans by borrower‟s
and businesses/farms of different sizes. Lastly, Arvest Bank makes a low level of community
development loans within Missouri assessment areas.
Lending Activity
The bank‟s lending levels in the state of Missouri reflect excellent responsiveness to assessment
area credit needs, based upon the lending activity analyzed under the Lending Test. This lending
Loan Type
Home Improvement
#
%
$(000s)
%
259
17.8%
12,340
7.3%
73
5.0%
6,283
3.7%
9
0.6%
6,989
4.2%
232
15.9%
16,832
10.0%
Total HMDA related
573
39.4%
42,444
25.2%
Small Business
747
51.3%
118,598
70.5%
Small Farm
136
9.3%
7,245
4.3%
1,456
100%
$168,287
100%
Home Purchase
Refinancing
TOTAL LOANS
121
Arvest Bank
January 10, 2011
As displayed in the following tables, Arvest Bank‟s overall performance under the geographic
distribution of loans criterion within the state of Missouri is adequate.
Missouri NonMSA
Adequate
Joplin MSA
Consistent
Springfield MSA
Below
Arvest Bank‟s overall loan distribution by borrower‟s profile reflects excellent performance,
based on activity in three Missouri assessment areas, as is detailed in the following tables.
Missouri NonMSA
Excellent
Joplin MSA
Below
Springfield MSA
Consistent
122
Arvest Bank
January 10, 2011
Overall, Arvest Bank makes a low level of community development loans within the state of
Missouri. The following table displays community development lending performance in the
bank‟s three Missouri assessment areas.
Missouri NonMSA
Few If Any
Joplin MSA
Exceeds
Springfield MSA
Consistent
Arvest Bank did not make any community development loans in the Missouri nonMSA
Assessment Area. The bank made one community development loan in the Springfield MSA
Assessment Area and two loans in the Joplin MSA Assessment Area; together, these three
community development loans in Missouri assessment areas totaled $0.7 million.
123
Arvest Bank
January 10, 2011
INVESTMENT TEST
For the state of Missouri, Arvest Bank‟s overall performance under the Investment Test is rated
low satisfactory. The following tables display investment and grant activity performance by
Missouri assessment areas.
Missouri NonMSA
Adequate
Joplin MSA
Consistent
Springfield MSA
Exceeds
Community development investments in Missouri assessment areas totaled $1.9 million, all of
which were made in MBS ($1.2 million in new investments and $0.7 million in previous review
period investments still outstanding). The bank also made community development grants
totaling $113,847 in Missouri assessment areas.
124
Arvest Bank
January 10, 2011
SERVICE TEST
Overall, Arvest Bank‟s performance in Missouri is rated low satisfactory under the Service Test.
The bank‟s delivery systems are reasonably accessible to geographies and individuals of
different income levels throughout Missouri assessment areas. In addition, the bank‟s record of
opening and closing branches has not adversely affected the accessibility of its delivery systems,
particularly to LMI geographies and/or LMI individuals. Business hours and services do not
vary in a way that inconveniences portions of Missouri assessment areas, particularly LMI
geographies and/or LMI individuals. Lastly, Arvest Bank provides few, if any, community
development services within its Missouri assessment areas.
As displayed in the following tables, the bank‟s delivery systems in Missouri assessment areas
are reasonably accessible to geographies and individuals of different income levels.
Missouri NonMSA
Joplin MSA
Consistent
Springfield MSA
Consistent
As displayed in the following tables, Arvest Bank‟s record of opening and closing branches in its
three Missouri assessment areas has not adversely affected the accessibility of its delivery
systems, particularly to LMI geographies and/or LMI individuals.
Missouri NonMSA
Joplin MSA
Consistent
Springfield MSA
Exceeds
125
Arvest Bank
January 10, 2011
portions of the bank‟s Missouri assessment areas, particularly LMI geographies and/or LMI
individuals. The bank‟s performance under this Service Test criterion is displayed by Missouri
assessment areas in the following tables.
Reasonableness of Business
Hours and Services
Missouri NonMSA
Reasonableness of Business
Hours and Services
Consistent
Joplin MSA
Springfield MSA
Consistent
Arvest Bank provides few, if any, community development services across its Missouri
assessment areas. The bank‟s performance under this Service Test criterion is displayed by
Missouri assessment areas in the following tables.
Missouri NonMSA
Few, If Any
Joplin MSA
Exceeds
Springfield MSA
Consistent
Arvest Bank did not provide any community development services in the Missouri nonMSA
Assessment Area, nor did the bank provide any community development services in the
Springfield MSA Assessment Area. Conversely, the bank had an adequate level of community
development services in the Joplin MSA Assessment Area.
126
Arvest Bank
January 10, 2011
JOPLIN, MISSOURI MSA
DESCRIPTION OF INSTITUTION’S OPERATIONS IN JOPLIN, MISSOURI MSA
This assessment area includes the entire Joplin, Missouri MSA, which is comprised of Jasper
County and Newton County. Arvest Bank operates 10 branch offices in this assessment area.
The tables below detail key demographics relating to this assessment area.
Dataset
Census Tracts
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
0
4
26
2
0
32
12.5%
81.3%
6.3%
4,269
35,559
3,048
10.0%
82.9%
7.1%
7,711
49,572
4,351
12.5%
80.4%
7.1%
1,101
5,961
557
14.5%
78.2%
7.3%
3
357
0.0%
0
Family
Population
0.0%
0
Household
Population
0.0%
0
Business
Institutions
0.0%
0
Agricultural
Institutions
0.0%
0.8%
97.8%
0.0%
0
0.0%
0
0.0%
0
0.0%
5
0
1.4%
0.0%
100%
42,876
100%
61,634
100%
7,619
100%
365
100%
Demographic Type
Family Population
Low7,479
17.4%
13,476
21.9%
Moderate8,305
19.4%
10,424
16.9%
127
Middle10,536
24.6%
12,723
20.6%
Upper16,556
38.6%
25,011
40.6%
TOTAL
42,876
100%
61,634
100%
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN JOPLIN,
MISSOURI MSA
LENDING TEST
Arvest Bank‟s overall lending performance in this assessment area is consistent with the Lending
Test performance for the state of Missouri, as displayed in the following table. For more detailed
information relating to the bank‟s Lending Test performance in this assessment area, see the
tables contained in Appendix C.
Performance
Lending Activity
Below
Consistent
Below
Exceeds
OVERALL
CONSISTENT
While the bank‟s performance under the lending activity and borrower‟s profile criteria is below
overall state performance, it is still adequate. The overall state of Missouri performance under
these criteria is excellent.
INVESTMENT TEST
Arvest Bank had community development investments of $569,923 (MBS purchased in a
previous review period still outstanding) and 31 grants for $72,162 attributable to this assessment
area, which is consistent with overall Investment Test performance for the state of Missouri.
SERVICE TEST
Service Test performance in the state of Missouri, as is detailed in the following table.
Performance
Consistent
Consistent
Consistent
Exceeds
OVERALL
CONSISTENT
128
Arvest Bank
January 10, 2011
SPRINGFIELD, MISSOURI MSA
DESCRIPTION OF INSTITUTION’S OPERATIONS IN SPRINGFIELD, MISSOURI
MSA
This assessment area includes the entire Springfield, Missouri MSA, which is comprised of the
following counties: Christian, Dallas, Greene, Polk, and Webster. Arvest Bank operates four
branch offices in this assessment area, three of which were opened during this review period.
The tables below detail key demographics relating to this assessment area.
Dataset
Census Tracts
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
2
18
44
21
0
85
21.2%
51.8%
24.7%
17,306
55,533
25,081
2.4%
Family
Population
225
0.2%
17.6%
56.6%
25.6%
Household
Population
1,593
29,216
81,033
33,676
1.1%
20.1%
55.7%
23.1%
Business
Institutions
446
3,176
10,473
5,207
2.3%
16.5%
54.3%
27.0%
Agricultural
Institutions
2
101
527
96
13.9%
72.6%
13.2%
0.3%
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
100%
98,145
100%
145,518
100%
19,302
100%
726
100%
Demographic Type
Family Population
TOTAL
Low-
Moderate-
Middle-
Upper-
17,103
17.4%
31,561
19,239
19.6%
25,176
23,652
24.1%
29,584
38,151
38.9%
59,197
98,145
100%
145,518
21.7%
17.3%
20.3%
40.7%
100%
129
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN SPRINGFIELD,
MISSOURI MSA
LENDING TEST
Test performance for the state of Missouri, as displayed in the following table. For more detailed
information relating to the bank‟s Lending Test performance in this assessment area, see the
tables contained in Appendix C.
Performance
Lending Activity
Consistent
Below
Consistent
Consistent
OVERALL
CONSISTENT
INVESTMENT TEST
Arvest Bank had community development investments of $1.1 million (MBS purchased in this
review period) and 12 grants for $34,520 attributable to this assessment area, which exceeds the
overall Investment Test performance for the state of Missouri.
130
Arvest Bank
January 10, 2011
SERVICE TEST
The bank‟s Service Test performance in this assessment area is consistent with overall Service
Test performance for the state of Missouri, as is detailed in the following table.
Performance
Consistent
Exceeds
Consistent
Consistent
OVERALL
CONSISTENT
Arvest Bank opened three branches in the Springfield MSA since the previous evaluation,
including one branch in a moderate-income census tract. This performance exceeds the overall
performance for the state of Missouri. Arvest Bank personnel did not provide any community
development services in this assessment area, which is consistent with overall Missouri
community development service performance.
131
Arvest Bank
January 10, 2011
NONMETROPOLITAN MISSOURI STATEWIDE AREA
(Full-Scope Review)
MISSOURI
Bank Structure
Arvest Bank has one assessment area within nonMSA Missouri, where it operates four of its 239
branches (1.7 percent). All four branches are located in middle-income census tracts. During
this review period, the bank opened one office in a middle-income census tract; no branches
were closed. Based on this branch network and other service delivery systems, the bank is
largely able to serve the primary central core of the nonMSA Missouri Assessment Area, with
secondary accessibility in the northwest and southeast portions of the assessment area.
Based on the FDIC Deposit Market Share Report as of June 30, 2010, 37 FDIC-insured
institutions operated at least one office within this assessment area, and the bank had the 27th
highest deposit market share percentage (1.7 percent). The deposits held at branches throughout
the nonMSA Missouri Assessment Area represent 0.6 percent of all Arvest Bank deposits.
The nonMSA Missouri Assessment Area is a ten-county area in the southwestern portion of the
state of Missouri, including the counties of Barry, Barton, Cedar, Dade, Douglas, Lawrence,
Ozark, Stone, Taney, and Vernon. While there are few towns with large populations in this
assessment area, it does include the city of Branson, which is a popular vacation destination for
people in Missouri and surrounding states. Based on 2000 census data, the assessment area had a
total population of 214,852. The county with the largest population is Taney County (39,703).
The remaining counties range in population from 7,923 to 35,204. According to U.S. Census
Bureau estimates as of July 2009, the population in the nonMSA Missouri assessment area has
grown to 229,311. This marks a total population increase of approximately 6.7 percent since the
2000 census.
132
Arvest Bank
January 10, 2011
As the demographics of this assessment area cover an expansive part of rural Missouri, credit
needs in the area are also varied, including a standard blend of consumer and business/farm
credit products. Other particular credit needs in the assessment area (as noted primarily during
community contact interviews) include increased access to credit for small businesses
(particularly, as related to business expansion and downtown area revitalization projects) and
consumer credit programs aimed at borrowers with seasonal employment. Further, many parts
of this assessment area are sparsely populated, and while there is significant need for community
development involvement, oftentimes these rural areas lack community development resources
from which to draw. Of the 40 middle-income census tracts in this assessment area, ten were
categorized as “underserved” and ten were “distressed” in 2009—two of which were both
underserved and distressed.41
The assessment area consists of 41 geographies. Based on the 2000 census, the median family
income for the assessment area was $35,198, which was significantly less than the state of
Missouri at $46,044, but similar to nonMSA Missouri, $35,821. As of 2009, the HUD estimated
median family income for nonMSA Missouri was $45,400. The following table summarizes the
distribution of geographies by income level and the family population of those census tracts
within the assessment area.
Dataset
Census Tracts
Family
Population
41
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
0
1
40
0
0
41
0.0%
0
0.0%
2.4%
97.6%
1,042
60,299
1.7%
98.3%
0.0%
0
0.0%
0.0%
0
0.0%
100%
61,341
100%
133
Arvest Bank
January 10, 2011
as the distribution of families for nonMSA Missouri overall.
Dataset
Assessment Area
NonMSA Missouri
Low-
Moderate-
Middle-
Upper-
TOTAL
11,230
11,901
15,112
23,098
61,341
18.3%
19.4%
24.6%
37.7%
100%
75,632
73,644
91,780
156,006
397,062
19.0%
18.6%
23.1%
39.3%
100%
Housing in the nonMSA Missouri Assessment Area is less affordable than nonMSA Missouri
overall. The nonMSA Missouri Assessment Area had a housing affordability ratio of 41.0
percent as of the 2000 census, which indicates that housing in the assessment area was less
affordable than nonMSA Missouri overall (45.0 percent). Of the ten counties in this assessment
area, housing was most affordable in Barton County (49.0 percent), while Stone County had the
lowest affordability ratio (35.0 percent). The median housing value in the assessment area was
$71,725, which is greater than the nonMSA Missouri figure, $65,152. The median gross
monthly rent in the assessment area ($403) was also higher than the nonMSA Missouri figure
($375).
agricultural entities operating within the nonMSA Missouri Assessment Area. Based on this
134
Arvest Bank
January 10, 2011
Total
Businesses
905
1,797
861
270
1,184
134
301
674
203
463
13
13
1,566
730
124
547
1,462
329
29
416
Industry
Construction
Information
Manufacturing
Mining
Retail Trade
Transportation
Utilities
Wholesale Trade
TOTAL
12,021
% of Total
7.5%
14.9%
7.2%
2.2%
9.8%
1.1%
2.5%
5.6%
1.7%
3.9%
0.1%
0.1%
13.0%
6.1%
1.0%
4.6%
12.2%
2.7%
0.2%
3.5%
100%
administrative, support, waste and removal services; other services; and retail trade. The average
annual unemployment rates in the assessment area varied significantly by county. The lowest
2008 average annual unemployment rate was 4.8 percent (Lawrence County), and the highest
rate was 9.2 percent (Barton County). In 2009, 8.0 percent was the lowest average annual
unemployment rate (Vernon County), and the highest unemployment rate was 12.1 percent
(Taney County). In comparison, the average annual unemployment rates for the state of
Missouri were 6.1 percent in 2008 and 9.3 percent in 2009.42
42
135
Arvest Bank
January 10, 2011
According to community contacts, communities in the southwest corner of nonMSA Missouri
have seen population increases in the last ten years, due to the benefits of a decreased cost of
living. With the influx in population, the economy has responded with more jobs in the tourism
sector, as well as a growing number of women- and minority-owned businesses. In light of these
circumstances, primary credit needs in this area are related to residential real estate and small
business lending. In particular, there is healthy demand for downtown revitalization in the
smaller communities. It was noted that due to the current sluggish economy, businesses have
been forced to maintain operations with fewer resources. As a result, it seems as though business
expansion is being hindered by restrictive credit standards, particularly for small businesses
experiencing lower profits due to current economic conditions. In contrast, credit standards for
home loans have been more flexible, which has kept the housing market steady. Arvest Bank
was specifically noted as being active in small business lending initiatives, and local banks in
general have been involved in education programs and small business owner workshops.
136
Arvest Bank
January 10, 2011
CONCLUSIONS
WITH
RESPECT
NONMETROPOLITAN MISSOURI
TO
PERFORMANCE
TESTS
IN
LENDING TEST
Lending levels reflect excellent responsiveness to nonMSA Missouri Assessment Area credit
and businesses/farms of different sizes. However, for the second consecutive CRA evaluation,
the bank did not make any community development loans in the nonMSA Missouri Assessment
Area.
Lending Activity
The bank‟s lending levels within the nonMSA Missouri Assessment Area reflect excellent
Loan Type
#
%
$(000s)
%
Home Improvement
55
14.9%
$3,435
8.5%
Home Purchase
30
8.1%
$2,752
6.8%
1
0.3%
$34
0.1%
62
16.8%
$6,423
15.9%
Total HMDA related
148
40.0%
$12,644
31.4%
Small Business
174
47.0%
$24,876
61.7%
48
13.0%
$2,784
6.9%
370
100%
$40,304
100%
Refinancing
Small Farm
TOTAL LOANS
As noted in the Description of Institution’s Operations in nonMSA Missouri section, this
assessment area has does not contain any low-income census tracts and only has one moderateincome census tract (2.4 percent of all assessment area census tracts). Overall, based on lending
activity from all three loan categories reviewed, the geographic distribution of loans reflects
adequate penetration throughout the assessment area. The following table displays the
for the assessment area.
137
Arvest Bank
January 10, 2011
Dataset
Home Purchase
Refinance
Home
Improvement
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
117
0
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
100%
202
100.0%
14
100%
0
1
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
TOTAL
117
100%
202
100%
14
100%
1
Multi-Family
0.0%
TOTAL
LOANS
Owner Occupied
Housing
0
0.0%
0
100.0%
334
0.0%
0
0.0%
0
100%
334
0.0%
0.0%
100%
0.0%
0.0%
100%
0.0%
1.8%
98.2%
0.0%
0.0%
100%
As displayed in the preceding table, the bank did not make any loans in the assessment area‟s
only moderate-income census tract. Nevertheless, based on the bank‟s performance context, the
geographic distribution of HMDA loans is adequate. As noted in the Description of Institution’s
Operations in nonMSA Missouri section, the bank‟s service accessibility is limited in the extreme
southwest portion of the assessment area, where the moderate-income census tract is located.
Furthermore, the moderate-income census tract presents minimal residential real estate lending
opportunity, as it accounts for a small percentage of owner-occupied housing units in the
assessment area (1.8 percent). Based on 2009 HMDA aggregate lending activity in the
assessment area, other lenders made less than one percent of HMDA loans in this moderateincome census tract. Therefore, in light of performance context relating to the bank‟s limited
service accessibility in the southwestern section of the assessment area, coupled with the
minimal lending opportunity presented in the moderate-income census tract, the bank‟s
geographic distribution of HMDA loans is adequate.
138
Arvest Bank
January 10, 2011
Next, the bank‟s geographic distribution of small business and small farm loans was reviewed,
which is displayed in the following tables in comparison to the location of businesses/farms
throughout the bank‟s assessment area.
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
107
0
0
0.0%
0.0%
0.0%
0.2%
100.0%
99.8%
0.0%
0.0%
0.0%
0.0%
TOTAL
107
100%
100%
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
32
0
0
0.0%
0.0%
0.0%
0.8%
100.0%
99.2%
0.0%
0.0%
0.0%
0.0%
TOTAL
32
100%
100%
As displayed in the preceding tables, the bank did not make any small business/farm loans in the
assessment area‟s only moderate-income census tract. Nevertheless, based on the bank‟s
performance context, the geographic distribution of these loans is adequate. As noted previously,
the moderate-income census tract is located in the extreme southwestern portion of the
assessment area, where the bank‟s service accessibility is limited. Furthermore, the moderateincome census tract presents minimal business/farm lending opportunity, as less than one percent
of assessment area businesses/farms are located in this census tract. Based on 2009 CRA
aggregate lending activity in the assessment area, other lenders made less than one percent of
business/farm loans in this moderate-income census tract. Therefore, in light of performance
context relating to the bank‟s limited service accessibility in the southwestern section of the
assessment area, coupled with the minimal lending opportunity presented in the moderateincome census tract, the bank‟s geographic distribution of small business and small farm loans is
adequate.
139
Arvest Bank
January 10, 2011
demographics.
Dataset
Home Purchase
Refinance
Home
Improvement
Low-
Moderate-
Middle-
Upper-
Unknown
4
31
25
57
0
26.5%
21.4%
48.7%
40
50
107
19.8%
24.8%
53.0%
1
2
8
14.3%
57.1%
0
0
3.4%
5
2.5%
2
14.3%
0
7.1%
0
0.0%
0
0.0%
1
7.1%
TOTAL
117
100%
202
100%
14
100%
1
1
100.0%
100%
2
334
Multi-Family
TOTAL
LOANS
Families
0.0%
0.0%
0.0%
0.0%
11
72
77
172
3.3%
21.6%
23.1%
51.5%
0.6%
100%
18.3%
19.4%
24.6%
37.7%
0.0%
100%
While the bank‟s level of lending to low-income borrowers is poor, lending to moderate-income
borrowers is excellent. As displayed in the table above, the bank‟s level of lending to lowincome borrowers (3.3 percent) is below the percentage of low-income families in the
assessment area (18.3 percent), as well as the 2009 HMDA aggregate lending level to lowincome borrowers (4.7 percent). Alternatively, the bank‟s lending level to moderate-income
borrowers (21.6 percent) is above the percentage of moderate-income families within the
assessment area (19.4 percent) and the 2009 HMDA aggregate lending level to moderate-income
borrowers (14.6 percent). Therefore, the bank‟s overall distribution of HMDA loans among
customers of different income levels is good.
140
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
75
10
14
99
71.4%
9.5%
13.3%
94.3%
0
0
6
6
0.0%
0.0%
5.7%
5.7%
75
10
20
105
71.4%
9.5%
19.0%
100%
TOTAL
with revenues of $1 million or less. The highest concentration of these loans was in loan
available to small businesses in the assessment area. Based on Dun & Bradstreet estimates, 91.2
percent of businesses reporting for 2009 had revenues of $1 million or less. In addition, the
bank‟s level of lending to small businesses surpasses the 2009 CRA aggregate lending level, 23.2
percent. Therefore, the bank‟s level of lending to small businesses is excellent.
141
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
27
2
3
32
84.4%
6.3%
9.4%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
27
2
3
32
84.4%
6.3%
9.4%
100%
All of the bank‟s small farm loans made in this assessment area were originated to farmers with
revenues of $1 million or less. Additionally, the largest concentration of these loans was in loan
available to small farms in the assessment area. According to Dun & Bradstreet estimates, 99.2
percent of farms in the assessment area reported gross annual revenues of $1 million or less. The
bank‟s small farm lending is significantly higher than 2009 CRA aggregate data, which indicate
that 80.3 percent of small farm loans originated by other institutions were to small farms.
Therefore, the bank‟s distribution of small farm loans by borrower‟s revenue profile is excellent.
Arvest Bank did not make any community development loans in the nonMSA Missouri
Assessment Area during the review period, as was the case at the bank‟s previous CRA
evaluation.
142
Arvest Bank
January 10, 2011
INVESTMENT TEST
The bank made an adequate level of qualified community development investments and grants in
the nonMSA Missouri Assessment Area, exhibiting adequate responsiveness to credit and
community development needs in the assessment area. During this review period, the bank had
$211,955 in qualified investments attributable to this assessment area, which represents an
increase of $103,954 (96.3 percent) since the last CRA evaluation. All of the bank‟s qualified
investments are in MBS that finance affordable housing (MBS of $110,250 were purchased
during this review period, while $101,705 were purchased in a previous review period still
outstanding). Additionally, Arvest Bank made 10 community development grants totaling
$7,165 during this review period. Among the qualifying contributions were significant donations
to affordable housing organizations, food banks, and community service organizations that target
143
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s service delivery systems are reasonably accessible to the nonMSA Missouri
Assessment Area, and the bank‟s record of opening and closing branches has not adversely
affected the accessibility of its delivery systems to LMI geographies and/or LMI individuals.
Business hours and services do not vary in a way that inconveniences LMI geographies and/or
LMI individuals. Conversely, for the second consecutive CRA evaluation, the bank did not
provide any community development services in the nonMSA Missouri Assessment Area.
Arvest Bank operates four branch facilities within this assessment area, all of which are located
in middle-income census tracts. The fact that all of the bank‟s branches are located in middleincome census tracts is in line with assessment area demographics. Nearly all of the census
tracts in this assessment area are designated as middle-income (97.6 percent), and nearly all
households reside within middle-income census tracts (98.4 percent). Therefore, Arvest Bank‟s
delivery systems are reasonably accessible to the geographies and individuals of different income
levels in the nonMSA Missouri Assessment Area.
The bank‟s record of opening and closing branches in the nonMSA Missouri Assessment Area
has not adversely affected the accessibility of its delivery systems, particularly to LMI
geographies and/or to LMI individuals. The bank opened one branch during this review period,
which is located in a middle-income census tract.
Branch facility business hours are relatively consistent across all branches in the nonMSA
Missouri Assessment Area. Most branches have Saturday operating hours and offer extended
hours of operations in their lobby and drive-up facilities at some point during the week. Most
drive-thru facilities remain open until 6 p.m., Monday through Friday, and are open until noon
on Saturdays. All branches offer the same standard products, including low-cost checking and
savings accounts, certificates of deposit, real estate and consumer loans, and other services.
Arvest Bank did not provide any community development services in the nonMSA Missouri
Assessment Area during the reviewed period, as was the case for the bank‟s previous CRA
evaluation.
144
Arvest Bank
January 10, 2011
OKLAHOMA45
CRA RATING FOR OKLAHOMA: SATISFACTORY
High Satisfactory
High Satisfactory
Low Satisfactory
Major factors supporting the institution‟s CRA rating for Oklahoma include the following:
Arvest Bank‟s lending levels reflect good responsiveness to the credit needs of its Oklahoma
assessment areas.
throughout the Oklahoma assessment areas.
The overall distribution of loans by borrower‟s income/revenue profile reflects good
penetration among borrowers of different income levels and businesses/farms of different
sizes.
Arvest Bank makes a relatively high level of community development loans within the
Oklahoma assessment areas.
grants throughout the Oklahoma assessment areas.
Service delivery systems are accessible to geographies and individuals of different income
levels in Oklahoma assessment areas; further, changes in branch locations have not adversely
affected the accessibility of delivery systems, particularly to LMI geographies and/or LMI
individuals.
Arvest Bank personnel provides an adequate level of community development services
throughout the Oklahoma assessment areas.
45
The bank has branches located in Oklahoma that are also part of the Fort Smith multistate MSA. Consequently,
this statewide evaluation is adjusted so as not to reflect performance in the parts of Oklahoma contained within a
multistate MSA. Refer to the multistate MSA section of this report for the rating and evaluation of the
institution‟s performance in that area.
145
Arvest Bank
January 10, 2011
Arvest Bank has four separate assessment areas within Oklahoma, and scoping considerations
applicable to the review of the Oklahoma assessment areas are consistent with the overall CRA
examination scope, as presented in the Institution, Scope of Examination section. The bank‟s
performance within three of these assessment areas was reviewed using full-scope CRA
examination procedures, which formed the primary basis for the bank‟s overall ratings in the
state of Oklahoma. In light of branch structure, loan and deposit activity, and supervisory
history, performance in the Tulsa, Oklahoma MSA (Tulsa MSA) Assessment Area received
primary consideration, followed by the nonMSA Oklahoma Assessment Area, and the Lawton,
Oklahoma MSA (Lawton MSA) Assessment Area.
To augment the full-scope assessment area evaluations in Oklahoma, three community contact
interviews were conducted (and six community contacts, previously completed as part of
separate supervisory events, were referenced) in order to ascertain specific community credit
needs, community development opportunities, and local market conditions.46 Two interviews
took place in the Lawton MSA—one was with a representative from a chamber of commerce and
one was with a city official. The third community contact was with a single family housing
specialist, working in a north-central city in nonMSA Oklahoma.
DESCRIPTION OF INSTITUTION’S OPERATIONS IN OKLAHOMA
The bank operates 93 branches (38.9 percent of total branches) throughout the four CRA
assessment areas in the state of Oklahoma. The following table gives additional detail regarding
the bank‟s Oklahoma operations.
Offices %
Deposits47
($000s)
5
5.4%
$175,425
5.0%
Full Scope
Tulsa MSA
29
31.2%
$1,242,554
35.6%
Full Scope
NonMSA Oklahoma
32
34.4%
$1,209,260
34.6%
Full Scope
Oklahoma City MSA
27
29.0%
$864,614
24.8%
Limited Scope
STATE TOTAL
93
100%
$3,491,853
100%
N/A
Assessment Area
Lawton MSA
Offices
#
Deposits %
CRA Review
Procedures
Deposits attributable to the 93 Oklahoma branches total $3.5 billion, which equates 37.7 percent
of total bank deposits.
46
section, as applicable to the Oklahoma full-scope review assessment area in which the community contacts were
made.
47
146
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN OKLAHOMA
LENDING TEST
Arvest Bank‟s Lending Test performance in the state of Oklahoma is rated high satisfactory.
Lending levels reflect good responsiveness to Oklahoma assessment area credit needs. The
geographic distribution of loans analyses reflects adequate penetration throughout the Oklahoma
assessment areas. The loan distribution by borrower‟s income/revenue profile reflects good
penetration among customers of different income levels and businesses/farms of different sizes.
Lastly, Arvest Bank makes a relatively high level of community development loans in Oklahoma
assessment areas.
Lending Activity
The bank‟s lending levels in the state of Oklahoma reflect good responsiveness to assessment
area credit needs, based upon the lending activity analyzed under the Lending Test. This lending
Loan Type
Home Improvement
#
%
$(000s)
%
2,432
18.0%
85,358
8.6%
385
2.8%
31,414
3.2%
19
0.1%
24,380
2.5%
1,713
12.7%
106,026
10.7%
Total HMDA related
4,549
33.7%
247,178
24.9%
Small Business
6,426
47.5%
640,275
64.4%
Small Farm
2,542
18.8%
106,449
10.7%
13,517
100%
$993,902
100%
Home Purchase
Refinancing
TOTAL LOANS
147
Arvest Bank
January 10, 2011
As displayed in the following tables, Arvest Bank‟s overall performance under the geographic
distribution of loans criterion within the state of Oklahoma is adequate.
Lawton MSA
Adequate
Tulsa MSA
Poor
Oklahoma NonMSA
Adequate
Oklahoma City MSA
Consistent
Arvest Bank‟s overall loan distribution by borrower‟s profile reflects good performance, based
on activity in the four Oklahoma assessment areas, as is detailed in the following tables.
Lawton MSA
Good
Tulsa MSA
Good
Oklahoma NonMSA
Excellent
Oklahoma City MSA
Consistent
148
Arvest Bank
January 10, 2011
Arvest Bank makes a relatively high level of community development loans within the state of
Oklahoma. The following table displays community development loan performance in the bank‟s
four Oklahoma assessment areas.
Lawton MSA
Tulsa MSA
Leader
Oklahoma NonMSA
Oklahoma City MSA
Consistent
The bank made 24 community development loans totaling $78.1 million in Oklahoma
assessment areas.
149
Arvest Bank
January 10, 2011
INVESTMENT TEST
Overall, the bank‟s performance in the Oklahoma assessment areas is rated high satisfactory
under the Investment Test. The following tables display investment and grant activity
performance by Oklahoma assessment area.
Lawton MSA
Significant
Tulsa MSA
Significant
Oklahoma NonMSA
Excellent
Oklahoma City MSA
Consistent
Community development investments in Oklahoma assessment areas totaled $20.8 million—
$10.2 million in community development-related tax credits purchased during this review period
and $10.6 million in MBS ($4.7 million in new securities and $5.9 million in previous review
period investments still outstanding). The bank also made community development grants
totaling $866,473 in Oklahoma assessment areas.
150
Arvest Bank
January 10, 2011
SERVICE TEST
Overall, Arvest Bank‟s Service Test performance is rated low satisfactory in the state of
Oklahoma. The bank‟s service delivery systems are accessible to geographies and individuals of
different income levels throughout Oklahoma assessment areas. In addition, the bank‟s record of
opening and closing branches has not adversely affected the accessibility of its delivery systems,
particularly to LMI geographies and/or LMI individuals. Business hours and services do not
vary in a way that inconveniences portions of Oklahoma assessment areas, particularly LMI
geographies and/or LMI individuals. Lastly, Arvest Bank provides an adequate level of
community development services within Oklahoma assessment areas.
As displayed in the following tables, the bank‟s delivery systems in Oklahoma assessment areas
are accessible to geographies and individuals of different income levels.
Lawton MSA
Accessible
Tulsa MSA
Accessible
Oklahoma NonMSA
Readily Accessible
Oklahoma City MSA
Consistent
151
Arvest Bank
January 10, 2011
Arvest Bank‟s record of opening and closing branches in its four Oklahoma assessment areas has
Lawton MSA
Tulsa MSA
Oklahoma NonMSA
Improved Access
Oklahoma City MSA
Exceeds
portions of the bank‟s Oklahoma assessment areas, particularly LMI geographies and/or LMI
individuals. The bank‟s performance under this Service Test criterion is displayed by assessment
area in the following tables.
Lawton MSA
Services
Do Not Vary in a Way That Inconveniences
Tulsa MSA
Oklahoma NonMSA
Services
Consistent
Oklahoma City MSA
152
Arvest Bank
January 10, 2011
Arvest Bank provides an adequate level of community development services throughout its
Oklahoma assessment areas. The bank‟s performance under this Service Test criterion is
displayed by assessment area in the following tables.
Lawton MSA
Adequate
Tulsa MSA
Few, If Any
Oklahoma NonMSA
Adequate
Oklahoma City MSA
Consistent
153
Arvest Bank
January 10, 2011
LAWTON, OKLAHOMA MSA
(Full-Scope Review)
DESCRIPTION OF INSTITUTION’S OPERATIONS IN LAWTON, OKLAHOMA MSA
Bank Structure
Arvest Bank has designated the entire Lawton, Oklahoma MSA (Lawton MSA) as an assessment
area, within which the bank operates five of its 239 branches (2.1 percent). Of the five branches,
zero are in low-income census tracts, one is in a moderate-income census tract, three are in
middle-income census tracts, and one is located in an upper-income census tract. During the
review period, the bank did not open or close any branches in this assessment area. Based on
this branch network and other service delivery systems, the bank is adequately positioned to
deliver financial services to substantially all of the Lawton MSA.
The assessment area is a very competitive banking market, with 11 FDIC-insured institutions
operating within the Lawton MSA, based on the FDIC Deposit Market Share Report as of June
30, 2010. Of those 11 financial institutions, Arvest Bank ranked 5th with a deposit market share
of 14.2 percent. The deposits held at branches throughout the Lawton MSA represent 1.9
percent of all Arvest Bank deposits.
The Lawton MSA is comprised of one county, Comanche County, in southwestern Oklahoma.
Based on 2000 census data, the assessment area had a total population of 114,996. According to
U.S. Census Bureau estimates as of July 2009, the population in the Lawton MSA has declined
slightly. The total MSA population in 2009 was estimated at 113,228. This marks a total MSA
population decrease of approximately 1.5 percent since the 2000 census.
As the demographics of this assessment area cover an MSA with a diverse population, credit
needs in the area are also varied, including a standard blend of consumer and business credit
products. Other particular credit needs in the assessment area (as noted primarily during
community contact interviews) include flexible lending programs for startup businesses and
credit products geared specifically to first time homebuyers. Further, as the Lawton MSA is an
environment with significant need, coupled with an adequate source of community development
intermediaries (such as nonprofit agencies, higher education institutions, and government
assistance entities), there is a high level of community development opportunity available for
financial institution participation.
154
Arvest Bank
January 10, 2011
The Lawton MSA consists of 29 geographies. Based on the 2000 census, the median family
income for the Lawton MSA was $39,201, which is slightly below the state of Oklahoma at
$40,709. As of 2009, the HUD estimated median family income for the Lawton MSA was
$50,700. The following table summarizes the distribution of geographies by income level and
the family population of those census tracts within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
2
9
13
5
0
29
6.9%
31.0%
44.8%
17.2%
522
5,050
18,950
4,568
1.8%
17.4%
65.1%
15.7%
0.0%
0
100%
29,090
0.0%
100%
The following table displays the distribution of families by income level, as well as the income
distribution of all Oklahoma families.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
5,968
4,964
6,449
11,709
29,090
20.5%
17.1%
22.2%
40.3%
100%
187,672
168,813
200,838
370,380
927,703
20.2%
18.2%
21.7%
39.9%
100%
Oklahoma
Housing affordability in the Lawton MSA appears to be similar to that of the overall state of
Oklahoma. As of the 2000 census, the Lawton MSA affordability ratio (47.0 percent) was just
slightly below the affordability ratio for the state of Oklahoma (49.0 percent). The median
housing value in the Lawton MSA was $70,463, which is slightly above the state of Oklahoma
($67,700). The median gross monthly rent in the Lawton MSA ($452) is also similar to the state
of Oklahoma ($456).
155
Arvest Bank
January 10, 2011
agricultural entities operating within the Lawton MSA. The following table depicts employment
levels by industry, comparing the Lawton MSA economy to the state of Oklahoma using the
“Location Quotient”48 measure.
Lawton MSA - Employment by Industry
Industry
163
1,658
3,430
7,148
ND
2,631
3,612
4,018
4,722
ND
0.6%
5.8%
11.9%
24.9%
ND
9.2%
12.6%
14.0%
16.4%
ND
LQ Oklahoma
0.12
0.98
1.08
1.04
ND
1.36
0.89
0.85
1.38
ND
28,741
100%
N/A
Employment
Construction
Manufacturing
Information
Other Services
TOTAL
% of Total
As displayed in the previous table, the largest industries in the Lawton MSA are trade,
transportation, and utilities; leisure and hospitality; and education and health services. The
Lawton MSA industry mix is similar to the state of Oklahoma, with a greater reliance on leisure
and hospitality and financial activities and less reliance on natural resources and mining.
The annual average unemployment rate for the Lawton MSA was 3.7 percent in 2008, which was
the same as the annual average for the state of Oklahoma. In 2009, the Lawton MSA average
unemployment rate increased to 5.2 percent, but it did not keep pace with 2009 average for the
state of Oklahoma, which increased to 6.6 percent. The unemployment rate in the Lawton MSA
continued to rise in 2010 and was projected to be at 6.8 percent in January 2011, an increase of
1.6 percent from the 2009 average; the state of Oklahoma was projected to have an
unemployment rate of 6.9 percent in January of 2011.49
48
49
156
Arvest Bank
January 10, 2011
Community contacts stated that the Lawton MSA is a growing, thriving community with credit
needs equally spread among small business and residential real estate. The housing market has
remained steady, and new construction is still relatively high despite the national economic
downturn. Furthermore, the population is getting younger as new business opportunities arise,
and the racial composition has remained relatively the same in the past five to ten years. Within
the city limits of Lawton is the Ft. Sill Army Base, which supports a steady employment base.
One contact stated that the low cost of living in Lawton can partially be attributed to the ample
supply of labor provided by the spouses of service members, and that service members and their
families represent a significant demand for low-income housing in and around the base.
All banks in the area were noted as being generally proactive in creating community
relationships. Also, several banks were praised for their special first time homebuyer programs,
which assists those that would not otherwise qualify for home ownership. However, it was noted
that there is still unmet need relating to small business startup financing, downtown
redevelopment, and general community services (shelters for at-risk families and individuals,
counseling centers for LMI individuals, and job search assistance/training centers).
157
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN LAWTON,
OKLAHOMA MSA
LENDING TEST
Lending levels reflect excellent responsiveness to Lawton MSA Assessment Area credit needs.
The bank‟s overall geographic distribution of loans reflects adequate penetration throughout the
assessment area. Further, the overall distribution of loans by borrower‟s income/revenue profile
reflects good penetration among customers of different income levels and businesses/farms of
different sizes. Lastly, Arvest Bank makes a relatively high level of community development
loans in the Lawton MSA Assessment Area.
Lending Activity
The bank‟s lending levels within the Lawton MSA Assessment Area reflect excellent
Loan Type
#
%
$(000s)
125
15.6%
$4,342
6.6%
29
3.6%
$2,177
3.3%
3
0.4%
$192
0.3%
85
10.6%
$5,181
7.8%
Total HMDA related
242
30.1%
$11,892
18.0%
Small Business
529
65.9%
$52,474
79.2%
32
4.0%
$1,870
2.8%
803
100%
$66,236
100%
Home Improvement
Home Purchase
Refinancing
Small Farm
TOTAL LOANS
158
%
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Lawton MSA section, this assessment
area includes two low-income census tracts and nine moderate-income census tracts,
from all three loan categories reviewed, the bank‟s geographic distribution of loans reflects
adequate penetration throughout this assessment area, including the 11 LMI census tracts. The
following table displays the geographic distribution of HMDA loans in comparison to owneroccupied housing data for the assessment area.
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
10
42
16
0
14.7%
61.8%
23.5%
8
73
35
62.4%
29.9%
11
42
19
15.3%
58.3%
26.4%
2
1
0
66.7%
33.3%
0.0%
31
158
70
0.4%
11.9%
60.8%
26.9%
0.0%
100%
1.6%
15.8%
64.8%
17.9%
0.0%
100%
0.0%
1
0.9%
0
0.0%
0
6.8%
0.0%
0
0.0%
0
0.0%
0
68
100%
117
100%
72
100%
3
Multi-Family
0.0%
TOTAL
LOANS
Owner Occupied
Housing
1
0.0%
0
100%
260
The bank‟s performance based on the geographic distribution of HMDA loans varied between
low- and moderate-income categories. As noted in the preceding table, the bank only made one
loan in a low-income census tract, representing 0.4 percent of all 2009 HMDA-lending activity.
This performance is poor, compared to the percentage of owner-occupied housing units in lowincome census tracts (1.6 percent). The bank‟s performance is also below the 2009 Lawton
MSA HMDA aggregate lending level in low-income census tracts (0.6 percent). Conversely, the
bank‟s penetration of moderate-income census tracts is good. While the bank‟s percentage of
lending in moderate-income census tracts (11.9 percent) is below the owner-occupied housing
percentage (15.8 percent), it is above that of other lenders in the MSA, based on the 2009
HMDA aggregate lending level in moderate-income census tracts (9.7 percent). Therefore, the
bank‟s overall geographic distribution of loans is adequate.
159
Arvest Bank
January 10, 2011
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
18
78
137
72
0
5.9%
25.6%
44.9%
23.6%
10.4%
29.2%
48.1%
12.3%
0.0%
0.0%
TOTAL
305
100%
100%
The bank‟s performance based on the geographic distribution of small business loans varied
between low- and moderate-income categories. As noted in the table above, 5.9 percent of the
bank‟s small business loans were made in low-income census tracts, which is poor compared to
the estimated percentage of businesses located in low-income census tracts, 10.4 percent. The
bank‟s lending level in low-income census tracts is also below that of other lenders, based on
2009 Lawton MSA CRA aggregate data indicating that 11.5 percent of reported small business
loans were made in low-income census tracts. Conversely, the bank‟s performance in moderateincome tracts is good. While the bank‟s lending percentage in moderate-income tracts, 25.6
percent, is less than the estimated percentage of businesses in moderate-income census tracts,
29.2 percent, it is above the CRA aggregate lending level in moderate-income census tracts, 24.4
percent. Therefore, the bank‟s overall geographic distribution of small business loans is
adequate.
160
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
13
4
0
17
0.0%
0.0%
76.5%
23.5%
0.0%
100%
0.5%
7.4%
77.9%
14.2%
0.0%
100%
this assessment area. However, based on the limited loan volume from both 2008 and 2009, the
geographic distribution of small farm loans is adequate. Based on 2009 lending activity, the
bank did not make any small farm loans in LMI census tracts. This performance is poor, in light
of the fact that an estimated 7.9 percent of farms are located in LMI census tracts. Furthermore,
other lenders made 4.0 percent of small farm loans in LMI census tracts, based on 2009 CRA
aggregate lending activity within the assessment area.
Conversely, the geographic distribution of the bank‟s 2008 small farm loans is good. While the
bank only made 15 small farm loans in this assessment area during 2008, 13.3 percent of these
loans were made in low-income census tracts. This performance is well above the estimated
percentage of farms in low-income census tracts, 0.5 percent, and the 2008 CRA aggregate, lowincome geography lending level, 0.9 percent. The bank made 6.7 percent of 2008 small farm
loans in moderate-income census tracts, which is on par with the estimated percentage of farms
located in moderate-income census tracts, 7.4 percent, and the bank‟s moderate-income
geography lending level is above that of other lenders, based on 2008 CRA aggregate data, 4.7
percent. Therefore, while the bank‟s performance varied significantly between data years, the
overall geographic distribution of small farm loans is adequate.
161
Arvest Bank
January 10, 2011
all three loan categories reviewed. The following table shows the distribution of HMDA
reported loans by borrower income level in comparison to family population data.
Dataset
Home Purchase
Refinance
Home
Improvement
Low-
Moderate-
Middle-
Upper-
Unknown
4
10
15
35
4
14.7%
22.1%
51.5%
15
17
82
12.8%
14.5%
70.1%
12
15
35
16.7%
20.8%
48.6%
0
0
0
5.9%
2
1.7%
7
9.7%
0
5.9%
1
0.9%
3
4.2%
TOTAL
68
100%
117
100%
72
100%
3
3
100.0%
100%
260
Multi-Family
TOTAL
LOANS
Families
0.0%
0.0%
0.0%
0.0%
13
37
47
152
11
5.0%
14.2%
18.1%
58.5%
4.2%
20.5%
17.1%
22.2%
40.3%
0.0%
100%
100%
The bank‟s level of lending to LMI borrowers within the assessment area is good. Based on the
above table, the bank‟s level of lending to low-income borrowers (5.0 percent) is lower than the
low-income family population (20.5 percent). However, this performance is adequate, as the
bank‟s level of lending is higher than the 2009 HMDA aggregate lending level to low-income
borrowers in the assessment area (4.6 percent). Similarly, the bank‟s HMDA lending level to
moderate-income borrowers (14.2 percent) is lower than the percentage of moderate-income
families within the assessment area (17.1 percent), but the bank‟s performance is good compared
to the aggregate lending level to moderate-income borrowers (11.6 percent).
162
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$1,000
237
27
21
285
78.2%
8.9%
6.9%
94.1%
8
2
8
18
2.6%
0.7%
2.6%
5.9%
245
29
29
303
80.9%
9.6%
9.6%
100%
majority of its small business loans (94.1 percent) to businesses with revenues of $1 million or
less. The highest concentration of these loans was for loan amounts of $100,000 or less, which
businesses greatly surpasses that of other lenders, based on 2009 CRA aggregate lending in the
assessment area, 19.6 percent.
50
This analysis included 305 small business loans; however, two of these loans were removed from the sample
163
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
14
2
0
16
82.4%
11.8%
0.0%
94.1%
1
0
0
1
5.9%
0.0%
0.0%
5.9%
15
2
0
17
88.2%
11.8%
0.0%
100%
As displayed in the preceding table, the bank had a relatively low level of small farm loan
activity in this assessment area. However, based on the limited loan activity available for
review, the distribution of small farm loans by borrower‟s profile is good. A high percentage of
small farm loans (94.1 percent) was made to farms with revenues of $1 million or less. The
highest concentration of these loans was in loan amounts of $100,000 or less, which further
demonstrates the bank‟s willingness to make credit available to small farms in the assessment
area. According to Dun & Bradstreet estimates, 99.5 percent of farms in the assessment area
reported revenues of $1 million or less. Furthermore, the bank‟s small farm lending performance
is higher than the 2009 CRA aggregate level of lending to small farms, 91.4 percent.
Arvest Bank makes a relatively high level of community development loans in the Lawton MSA
Assessment Area. The bank made two community development loans totaling $6.3 million
during this review period. Both loans were for revitalization projects inside low-income census
tracts.
164
Arvest Bank
January 10, 2011
INVESTMENT TEST
grants within the Lawton MSA Assessment Area, exhibiting good responsiveness to credit and
community development needs in the assessment area. As of this evaluation date, the bank had a
community development investment balance of $515,130 attributable to this assessment area,
which represents an increase of 40.3 percent since the last CRA evaluation. All of these
community development investments are in MBS that finance affordable housing (MBS of
$211,913 were purchased during this review period, while $303,217 were purchased in a
previous review period still outstanding). Additionally, Arvest Bank made 34 grants totaling
$55,436 throughout the assessment area. Among these numerous grants were significant
donations to schools serving a majority of students from LMI families, affordable housing
organizations, and community service organizations that assist the needy.
165
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s service delivery systems are accessible to the Lawton MSA Assessment Area, and
the bank‟s record of opening and closing branches has not adversely affected the accessibility of
its delivery systems to LMI geographies and/or LMI individuals. Business hours and services do
not vary in a way that inconveniences LMI geographies and/or LMI individuals. Lastly, the
bank provides an adequate level of community development services in the Lawton MSA
Assessment Area.
Arvest Bank operates five branch facilities within the Lawton MSA. The following table
illustrates the distribution of these facilities by income level of the geography, as compared to
key assessment area demographics.
Dataset
Branches
0
1
3
1
0
0.0%
20.0%
60%
20.0%
0.0%
TOTAL
5
100%
Census Tracts
6.9%
31.0%
44.8%
17.2%
0.0%
100%
Household
Population
2.5%
21.3%
61.5%
14.8%
0.0%
100%
While the bank does not operate any branches in low-income census tracts within the Lawton
MSA Assessment Area, the two low-income census tracts represent a very small part of the
overall assessment area, based on location of households (2.5 percent). Further, the bank is still
able to adequately serve these geographies, as there are several branches within a reasonable
distance of both low-income census tracts. The bank operates one branch in a moderate-income
census tract (20.0 percent), which is in line with the percentage of households within moderateincome census tracts (21.3 percent). Additionally, all five of the bank‟s branches are located
near the center of Lawton, where all of the LMI geographies are located. Based on this
information, the bank‟s service delivery systems are accessible to geographies and individuals of
different income levels in the Lawton MSA Assessment Area.
The bank‟s record of opening and closing branches in the Lawton MSA Assessment Area has not
adversely affected the accessibility of its delivery systems, particularly to LMI geographies
period.
166
Arvest Bank
January 10, 2011
the Lawton MSA Assessment Area. Most branches have Saturday operating hours and offer
extended hours of operations in their lobby and drive-up facilities at some point during the week.
Arvest Bank personnel provides an adequate level of community development services within
the Lawton MSA Assessment Area. Throughout the review period, two bank employees
provided financial expertise to community development organizations. One employee served as
board chairman of a community service organization aiding the needy in the city of Lawton. The
other employee served a school district with a majority of students from LMI families.
167
Arvest Bank
January 10, 2011
TULSA, OKLAHOMA MSA
(Full-Scope Review)
DESCRIPTION OF INSTITUTION’S OPERATIONS IN TULSA, OKLAHOMA MSA
Bank Structure
Arvest Bank has designated the entire Tulsa, Oklahoma MSA (Tulsa MSA) as an assessment
area within which the bank operates 29 of its 239 branches (12.1 percent). Of the 29 branches,
zero are in low-income census tracts, seven are in moderate-income census tracts, 12 are in
middle-income census tracts, and ten are located in upper-income census tracts. During the
review period, the bank did not open or close any branches in this assessment area. Based on
this branch network and other service delivery systems, the bank is adequately positioned to
deliver financial services to substantially all of the Tulsa MSA.
This assessment area is a highly competitive banking market, with a total of 66 FDIC-insured
institutions operating within the Tulsa MSA, based on the FDIC Deposit Market Share Report as
of June 30, 2010. Of those 66 financial institutions, Arvest Bank ranked 3rd with a deposit
market share of 6.5 percent. The deposits held at branches throughout the Tulsa MSA represent
13.4 percent of all Arvest Bank deposits.
The Tulsa MSA is a seven-county area in northeastern Oklahoma. The seven counties
comprising the MSA are Creek, Okmulgee, Osage, Pawnee, Rogers, Tulsa, and Wagoner. Based
on 2000 census data, the assessment area had a total population of 859,532. The majority of the
population lives in Tulsa County (563,299). The remaining counties range in population from
16,612 (Pawnee County) to 70,641 (Rogers County). According to U.S. Census Bureau
estimates as of July 2009, the population in the Tulsa MSA has grown to 929,015, marking an
increase of approximately 8.1 percent since the 2000 census.
As the demographics of this assessment area cover a wide metropolitan area and the population
primarily during community contact interviews) include general banking services geared towards
LMI individuals (particularly those in need of reestablishing credit history), foreclosure
prevention assistance, and financial education programs for first time home buyers and small
business entrepreneurs. Further, as the Tulsa MSA is an environment with significant need,
coupled with a strong source of community development intermediaries (such as nonprofit
agencies, higher education institutions, and government assistance entities) there is a high level
of community development opportunity available for financial institution participation.
168
Arvest Bank
January 10, 2011
The MSA consists of 264 geographies. Based on the 2000 census, the median family income for
the Tulsa MSA was $45,678, which was greater than the state of Oklahoma at $40,709. As of
2009, the HUD estimated median family income for the Tulsa MSA was $57,600. The following
table summarizes the distribution of geographies by income level and the family population of
those census tracts within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
7
67
111
79
0
264
2.7%
25.4%
42.0%
29.9%
3,612
53,078
108,176
67,361
1.6%
22.9%
46.6%
29.0%
0.0%
0
100%
232,227
0.0%
100%
The following table displays the distribution of families, by income level, that reside in this
assessment area as well as the statewide percentage for Oklahoma.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
46,267
42,578
50,189
93,193
232,227
19.9%
18.3%
21.6%
40.1%
100%
187,672
168,813
200,838
370,380
927,703
20.2%
18.2%
21.6%
39.9%
100%
Oklahoma
While income levels in the assessment area are relatively higher than income levels for the state
of Oklahoma overall, higher housing costs in the Tulsa MSA keep overall housing affordability
in the assessment area below that of the state. As of the 2000 census, the Tulsa MSA
Assessment Area housing affordability ratio (46.0 percent) was less than the affordability ratio
for state of Oklahoma (49.0 percent). Of the seven MSA counties, buying a home is most
affordable in Pawnee County (60.0 percent) and least affordable in Tulsa County (44.0 percent).
The median housing value in the assessment area ($79,950) is significantly higher than that of
the state of Oklahoma ($67,700). The median gross monthly rent in the Tulsa MSA is also
higher ($503) than the state of Oklahoma figure ($456). These numbers show that the Tulsa
MSA is less affordable than the state of Oklahoma as a whole.
169
Arvest Bank
January 10, 2011
agricultural entities operating within the Tulsa MSA. The following table depicts employment
levels by industry, comparing the Tulsa MSA economy to the state of Oklahoma using the
“Location Quotient”51 measure.
Tulsa MSA - Employment by Industry
Industry
7,412
20,643
46,548
83,057
9,070
23,220
54,366
55,795
37,059
10,451
2.1%
5.9%
13.4%
23.9%
2.6%
6.7%
15.6%
16.1%
10.7%
3.0%
LQ Oklahoma
0.46
1.01
1.21
1.00
1.11
0.99
1.11
0.98
0.89
0.97
347,621
100%
N/A
Employment
Construction
Manufacturing
Information
Other Services
TOTAL
% of Total
As displayed in the previous table, the largest industries in the Tulsa MSA are trade,
transportation, and utilities; education and health services; and professional and business
services. The Tulsa MSA industry mix is similar to the state of Oklahoma, with a greater
reliance on manufacturing and less reliance on natural resources and mining. The recent annual
average unemployment rates for the Tulsa MSA (3.7 percent in 2008 and 6.9 percent in 2009)
are similar to the average unemployment rates for the state of Oklahoma (3.7 percent in 2008 and
6.6 percent in 2009).52
51
52
170
Arvest Bank
January 10, 2011
Community contacts stated that the Tulsa economy has been well insulated from the losses that
many area economies are experiencing. Furthermore, when Tulsa experiences the impact of
negative economic conditions, the area recovers quickly. Yet, there is still strong need for
community development in Tulsa, particularly as related to LMI housing and small businesses.
Related to affordable housing needs, contacts said that area banks could provide more resources
focused on home ownership education, down payment assistance, and foreclosure prevention. In
addition, residents who are renting properties would benefit from programs aimed at obtaining
initial security deposits and maintaining utility services. Community contacts felt that LMI
residents need more general banking services geared toward them, especially for those that have
tarnished credit.
Opportunities are available for area financial institutions to finance small businesses, particularly
in land development projects, as the cost of available space for manufacturing and retail
development has increased significantly. These financing arrangements will also help attract
new businesses, meet the area‟s growing need for retail services, and support new job growth.
Additionally, financial expertise is needed in the areas of business plan review, credit history
management, and businesses start-up financing. Overall, community contacts stated that many
area financial institutions are visible in the community, providing both financial and nonfinancial
assistance to area businesses.
171
Arvest Bank
CONCLUSIONS WITH
OKLAHOMA MSA
January 10, 2011
RESPECT
TO
PERFORMANCE
TESTS
IN
TULSA,
LENDING TEST
Lending levels reflect good responsiveness to Tulsa MSA Assessment Area credit needs. The
geographic distribution of loans reflects poor penetration throughout the assessment area, but the
loan distribution by borrower‟s income/revenue profile reflects good penetration among
customers of different income levels and businesses/farms of different sizes. Lastly, Arvest
Bank is a leader in making community development loans in the Tulsa MSA Assessment Area.
Lending Activity
The bank‟s lending levels within the Tulsa MSA reflect good responsiveness to assessment area
credit needs based upon the lending activity analyzed under the Lending Test. This lending
Loan Type
#
%
$(000s)
%
1,080
25.1%
$36,920
9.1%
148
3.4%
$16,170
4.0%
5
0.1%
$11,102
2.7%
622
14.4%
$40,927
10.1%
Total HMDA related
1,855
43.0%
$105,119
25.8%
Small Business
2,219
51.5%
$287,187
70.6%
236
5.5%
$14,605
3.6%
4,310
100%
$406,911
100%
Home Improvement
Home Purchase
Refinancing
Small Farm
TOTAL LOANS
172
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in Tulsa MSA section, this assessment
area includes seven low-income census tracts and 67 moderate-income census tracts,
from all three loan categories reviewed, the bank‟s geographic distribution of loans reflects poor
penetration throughout this assessment area, particularly among the 74 LMI census tracts. The
following table displays the geographic distribution of HMDA loans in comparison to owneroccupied housing demographics for the assessment area.
Dataset
Home Purchase
Refinance
Home
Improvement
Low-
Moderate-
Middle-
Upper-
Unknown
2
57
229
292
0
9.8%
39.5%
50.3%
48
330
503
5.4%
37.4%
57.0%
49
223
223
9.8%
44.8%
44.8%
0
1
0.3%
1
0.1%
3
0.6%
0
3
0.0%
0
0.0%
0
0.0%
0
TOTAL
580
100%
882
100%
498
100%
4
Multi-Family
0.0%
TOTAL
LOANS
Owner Occupied
Housing
6
75.0%
0.0%
25.0%
157
782
1,019
0.0%
0
100%
1,964
0.3%
8.0%
39.8%
51.9%
0.0%
100%
0.9%
20.8%
47.4%
30.8%
0.0%
100%
While overall lending levels to borrowers in LMI census tracts were low, the bank‟s geographic
distribution of HMDA loans still appears to be marginally adequate, particularly when compared
to the performance of other lenders. As displayed in the table above, the bank‟s level of lending
in low-income census tracts (0.3 percent) is less than the percentage of owner-occupied housing
units in low-income geographies (0.9 percent); however, this performance is still adequate, as it
equals the low-income census tract lending level made by other lenders, based on 2009 HMDA
aggregate lending activity in the Tulsa MSA. Conversely, the bank‟s lending level in moderateincome census tracts (8.0 percent) is poor, as it is below both the percentage owner-occupied
housing units in moderate-income geographies (20.8 percent) and the aggregate lending level
(9.7 percent). In summary, the bank‟s combined LMI geography lending level (8.3 percent) is
low; however, it is within range of the combined LMI lending level of other lenders (10.0
percent), reflecting adequate performance.
173
Arvest Bank
January 10, 2011
displayed in the following table compared to the distribution of assessment area businesses by
geography income level.
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
2
189
435
705
0
14.2%
32.7%
53.0%
23.9%
41.6%
33.3%
0.2%
1.1%
0.0%
0.0%
TOTAL
1,331
100%
100%
The analysis of the bank‟s small business loan activity reflects poor penetration throughout the
assessment area. The bank‟s low-income census tract lending level (0.2 percent) is poor
compared to the percentage of businesses within these geographies (1.1 percent) and the 2009
Tulsa MSA CRA aggregate lending level in low-income census tracts (0.9 percent). The bank‟s
performance in moderate-income tracts is also poor, as the bank‟s percentage of small business
loans in moderate-income tracts (14.2 percent) is less than the percentage of businesses located
in these geographies (23.9 percent) and the aggregate lending level (20.8 percent).
Finally, the geographic distribution of small farm loans is displayed in the following table,
compared to the distribution of assessment area farms by geography income level.
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
15
91
9
0
13.0%
79.1%
7.8%
24.8%
57.0%
18.1%
0.0%
0.1%
0.0%
0.0%
TOTAL
115
100%
100%
The bank‟s geographic distribution of small farm loans is poor. While the level of opportunity to
make small farm loans in low-income census tracts is negligible, 24.8 percent of assessment area
farms are located in moderate-income census tracts; however, the bank‟s level of lending in
moderate-income geographies, 13.0 percent, is well below the demographic figure. The bank‟s
level of lending in moderate-income census tracts is also significantly below that of other
lenders, 26.8 percent, based 2009 CRA aggregate data.
174
Arvest Bank
January 10, 2011
all three loan categories reviewed. The following table shows the distribution of HMDA
demographics.
Dataset
Home Purchase
Refinance
Home
Improvement
Low-
Moderate-
Middle-
Upper-
Unknown
62
149
139
221
9
10.7%
25.7%
24.0%
38.1%
1.6%
59
145
210
453
15
6.7%
16.4%
23.8%
51.4%
1.7%
90
111
242
12
18.1%
22.3%
48.6%
2.4%
0
0
0
43
8.6%
0
TOTAL
580
100%
882
100%
498
100%
4
4
100.0%
100%
40
1,964
Multi-Family
TOTAL
LOANS
Families
0.0%
0.0%
0.0%
0.0%
164
384
460
916
8.4%
19.6%
23.4%
46.6%
2.0%
100%
19.9%
18.3%
21.6%
40.1%
0.0%
100%
The bank‟s level of lending to both low-income and moderate-income borrowers within the
assessment area is good. Based on the above table, the bank‟s level of lending to low-income
borrowers (8.4 percent) is lower than the percentage of low-income families (19.9 percent);
however, the bank‟s performance is significantly higher than that of other lenders (6.5 percent),
based on 2009 Tulsa MSA HMDA aggregate data. Furthermore, the bank‟s HMDA lending
percentage to moderate-income borrowers (19.6 percent) is above the percentage of moderateincome borrowers within the assessment area (18.3 percent), and it similar to aggregate lending
to moderate-income borrowers (19.7 percent).
175
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250 <$1,000
939
95
89
1,123
71.1%
7.2%
6.7%
85.0%
70
51
77
198
5.3%
3.9%
5.8%
15.0%
1,009
146
166
1,321
76.4%
11.1%
12.6%
100%
The bank‟s level of lending to small businesses is good. The bank originated a strong majority
of its small business loans (85.0 percent) to businesses with gross annual revenues of $1 million
or less. The highest concentration of these loans was in amounts of $100,000 or less, which
businesses is well above that of other lenders (19.0 percent) based on 2009 CRA aggregate data.
53
This analysis included 1,331 small business loans; however, ten of these loans were removed from the sample
176
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
100
10
5
115
87.0%
8.7%
4.3%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
100
10
5
115
87.0%
8.7%
4.3%
100%
Arvest Bank‟s lending to small farms is excellent. All small farm loans made in this assessment
area were originated to farmers with gross annual revenues $1 million or less. The highest
concentration of these loans was in loan amounts of $100,000 or less, which further demonstrates
the bank‟s willingness to make credit available to small farms in the assessment area. According
to Dun & Bradstreet estimates, 98.9 percent of farms in the assessment area reported revenues of
$1 million or less. The bank‟s level of lending to small farms is significantly higher than that of
other lenders (70.6 percent) based on 2009 CRA aggregate data.
Arvest Bank continues to be a leader in making community development loans in the Tulsa
MSA. The bank originated or renewed nine community development loans totaling $52.0
million during this review period. Five of the loans financed projects that revitalize or stabilize
LMI geographies. Three of the loans were to community service agencies serving LMI
individuals in the Tulsa MSA, and two loans were for affordable housing targeted to LMI
individuals and families.
177
Arvest Bank
January 10, 2011
INVESTMENT TEST
grants within the Tulsa MSA. As of the evaluation date, the bank had a community development
investment balance of $5.5 million attributable to this assessment area. Of this balance, $4.0
million is invested in MBS that finance affordable housing (MBS of $1.8 million were purchased
during this review period, while $2.2 million were purchased in a previous review period still
outstanding). In addition, the bank has investments in projects associated with LIHTCs that total
$100,000 and NMTCs that total $1.4 million. Arvest Bank also made a significant level of
qualified community development grants within the Tulsa MSA. The bank made 49 community
development grants totaling $281,260 during this review period. Among the numerous
contributions were significant grants to schools serving a majority of students from LMI
families, affordable housing organizations, and community service organizations targeting the
needs of LMI families.
Community Development Initiatives
As noted above, the bank makes significant use of LIHTC and NMTC investments to further
community development in the Tulsa MSA. LIHTCs fund the construction of new rental
housing and rehabilitation of existing housing for low-income households. NMTCs provide
equity capital to further commercial economic development activities in underserved
geographies.
Responsiveness to Credit and Community Development Needs
Arvest Bank exhibits good responsiveness to credit and community development needs in the
Tulsa MSA Assessment Area. Community contacts noted that the major credit needs in the area
are related to residential real estate and small businesses financing. The bank made numerous
donations to affordable housing agencies, made significant use of LIHTC investments, and
invested in MBS that finance affordable housing for LMI homeowners. Additionally, NMTC
investments further commercial economic development, where it is needed most in the Tulsa
MSA.
178
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s service delivery systems are accessible to the Tulsa MSA Assessment Area, and
the bank‟s record of opening and closing branches has not adversely affected the accessibility of
its delivery systems to LMI geographies and/or LMI individuals. Business hours and services do
not vary in a way that inconveniences LMI geographies and/or LMI individuals. Conversely, the
bank provides few community development services in the Tulsa MSA Assessment Area.
Arvest Bank operates 29 branch facilities within the Tulsa MSA. The following table illustrates
the distribution of these facilities by income level of the geography, as compared to key
assessment area demographics.
Dataset
Branches
0
7
12
10
0
0.0%
24.1%
41.4%
34.5%
0.0%
TOTAL
29
100%
Census Tracts
2.7%
25.4%
42.0%
29.9%
0.0%
100%
Household
Population
1.8%
24.5%
46.4%
27.3%
0.0%
100%
While the bank does not operate any branches in low-income census tracts within the Tulsa MSA
Assessment Area, these geographies represent a very small part of the overall assessment area,
based on location of households (1.8 percent). The bank operates seven branches in moderateincome census tracts (24.1 percent), which is in line with the percentage of households within
moderate-income census tracts (24.5 percent). Based on this information, the bank‟s service
delivery systems are accessible to geographies and individuals of different income levels in the
Tulsa MSA Assessment Area.
The bank‟s record of opening and closing branches in the Tulsa MSA Assessment Area has not
adversely affected the accessibility of its delivery systems, particularly to LMI geographies
period.
179
Arvest Bank
January 10, 2011
the Tulsa MSA Assessment Area. Most branches have Saturday operating hours and offer
extended hours of operations in their lobby and drive-up facilities at some point during the week.
Arvest Bank personnel provides few community development services in the Tulsa MSA
Assessment Area. During this review period, one bank employee served on the board of
directors of an organization assisting at-risk, LMI families and individuals in Tulsa.
180
Arvest Bank
January 10, 2011
OKLAHOMA CITY, OKLAHOMA MSA
DESCRIPTION OF
OKLAHOMA MSA
INSTITUTION’S
OPERATIONS
IN
OKLAHOMA
CITY,
Arvest Bank designated the entire Oklahoma City, Oklahoma MSA (Oklahoma City MSA) as an
assessment area. The Oklahoma City MSA is located in central Oklahoma and is comprised of
seven counties: Canadian, Cleveland, Grady, Lincoln, Logan, McClain, and Oklahoma. The
bank operates 27 branches in the Oklahoma City MSA, and, during the review period, the bank
opened two branches—one in a moderate-income census tract and one in a middle-income
census tract.
Dataset
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
24
100
122
83
5
334
7.2%
29.9%
36.5%
24.9%
Family
Population
7,706
72,954
115,738
93,249
2.7%
25.2%
40.0%
32.2%
Household
Population
13,483
119,272
171,877
125,183
176
429,991
3.1%
27.7%
40.0%
29.1%
< 0.1%
100%
Business
Institutions
2,199
12,195
20,546
18,075
1,042
54,057
4.1%
22.6%
38.0%
33.4%
1.9%
100%
Agricultural
Institutions
7
194
577
342
17.3%
51.4%
30.5%
Census Tracts
0.6%
1.5%
0
0.0%
3
0.3%
100%
289,647
100%
1,123
100%
Assessment Area Demographics by Income Level of Population
Demographic Type
Family Population
TOTAL
Low-
Moderate-
Middle-
Upper-
58,024
20.0%
97,636
52,668
18.2%
71,713
62,751
21.7%
83,935
116,204
40.1%
176,707
289,647
100%
429,991
22.7%
16.7%
19.5%
41.1%
100%
181
Arvest Bank
January 10, 2011
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN OKLAHOMA
CITY, OKLAHOMA MSA
LENDING TEST
Test performance for the state of Oklahoma, as displayed in the following table. For more
detailed information relating to the bank‟s Lending Test performance in this assessment area, see
the tables contained in Appendix C.
Performance
Lending Activity
Below
Consistent
Consistent
Consistent
OVERALL
CONSISTENT
INVESTMENT TEST
Arvest Bank had community development investments of $569,923 (MBS purchased in a
previous review period still outstanding) and 31 grants for $72,162 attributable to this assessment
area, which is consistent with overall Investment Test performance for the state of Missouri.
For this review period, Arvest Bank had outstanding community development investments
totaling $4.0 million ($2.5 million in MBS purchased in this review period and $1.5 million
purchased in a previous review period still outstanding) and 63 grants totaling $186,048 in the
Oklahoma City MSA Assessment Area, which is consistent with overall Investment Test
performance for the state of Oklahoma.
182
Arvest Bank
January 10, 2011
SERVICE TEST
Service Test performance in state of Oklahoma, as is detailed in the following table.
Performance
Consistent
Exceeds
Consistent
Consistent
OVERALL
CONSISTENT
183
Arvest Bank
January 10, 2011
NONMETROPOLITAN OKLAHOMA STATEWIDE
AREA
(Full-Scope Review)
OKLAHOMA
Bank Structure
Arvest Bank has one assessment area within nonMSA Oklahoma, where it operates 32 of its 239
branches (13.4 percent). Of the 32 branches, one is in a low-income census tract, five are in
moderate-income census tracts, 21 are in middle-income census tracts, and five are located in
upper-income census tracts. Based on this branch network and other service delivery systems,
the bank is largely able to serve most of this geographically expansive assessment area, with
secondary accessibility in the extreme northwest and southeast portions of the assessment area.
This assessment area covers a large portion of the state of Oklahoma, where 142 FDIC-insured
institutions operate at least one office, based on the FDIC Deposit Market Share Report as of
June 30, 2010. Of these 142 financial institutions, Arvest Bank ranked 3rd with a deposit market
share of 6.7 percent. Based on this information, Arvest Bank deposits held at branches
throughout nonMSA Oklahoma represent 13.1 percent of the bank‟s total deposits.
The nonMSA Oklahoma Assessment Area covers most of the central and eastern portions of the
state of Oklahoma; it includes the following 43 counties: Adair, Atoka, Blaine, Bryan, Caddo,
Carter, Cherokee, Choctaw, Coal, Cotton, Craig, Delaware, Garfield, Garvin, Grant, Haskell,
Hughes, Jefferson, Johnston, Kay, Kingfisher, Kiowa, Latimer, Love, McCurtain, McIntosh,
Marshall, Mayes, Murray, Muskogee, Noble, Nowata, Okfuskee, Ottawa, Payne, Pittsburg,
Pontotoc, Pottawatomie, Pushmataha, Seminole, Stephens, Tillman, and Washington. Based on
2000 census data, the assessment area had a total population of 1,112,239. The county with the
largest population is Muskogee County (69,451). The remaining counties ranged in population
from 5,144 (Grant County) to 68,190 (Payne County). According to U.S. Census Bureau
estimates as of July 2009, the population in the nonMSA Oklahoma Assessment Area has grown
to 1,134,338, marking a population increase of 2.0 percent since the 2000 census.
As the demographics of this assessment area cover an expansive part of rural Oklahoma,
business and personal credit needs in the area are varied, but there is heightened demand for
agricultural credit and housing-related credit. Other particular credit needs in the assessment
area (as noted primarily during community contact interviews) relate to credit products and
financial education (particularly related to credit history management) geared to the low-income
population. Further, many parts of this assessment area are sparsely populated, and while there
is significant need for community development involvement, oftentimes these rural areas lack
community development resources from which to draw. Of the 206 middle-income census tracts
184
Arvest Bank
January 10, 2011
in this assessment area, 93 were categorized as “distressed” and 11 were categorized as both
“underserved” and “distressed” in 2009.54
Based on the 2000 census data, the median family income for the assessment area was $35,230,
which was less than the state of Oklahoma figure, $40,709, but similar to the figure for nonMSA
Oklahoma overall, $35,517. As of 2009, the HUD estimated median family income for nonMSA
Oklahoma was $46,400. The following table summarizes the distribution of geographies by
income level and the family population of those census tracts within the assessment area.
Dataset
Census Tracts
Family
Population
Low-
Moderate-
Middle-
Upper-
Unknown
TOTAL
1
50
206
34
0
291
17.2%
70.8%
11.7%
43,266
212,448
47,898
14.2%
69.9%
15.8%
0.3%
323
0.1%
0.0%
0
100%
303,935
0.0%
100%
The following table displays the distribution of families by income level, as well as the
distribution of families for the state of for Oklahoma overall.
Dataset
Low-
Moderate-
Middle-
Upper-
TOTAL
Assessment
Area
62,740
55,344
65,368
120,483
303,935
20.6%
18.2%
21.5%
39.6%
100%
187,672
168,813
200,838
370,380
927,703
20.2%
18.2%
21.6%
39.9%
100%
Oklahoma
54
185
Arvest Bank
January 10, 2011
While income levels in the nonMSA Oklahoma Assessment Area are lower than those for the
state of Oklahoma overall, housing in the assessment appears to be relatively more affordable,
due to lower housing costs. The nonMSA Oklahoma Assessment Area had a housing
affordability ratio of 52.0 percent as of the 2000 census, which indicated greater affordability
relative to the state of Oklahoma figure, 49.0 percent. The median housing value in the
assessment area was $54,323, which is much lower than the state of Oklahoma at $67,700.
Median gross monthly rent in the assessment area is also lower at $391 than the state of
Oklahoma at $456.
agricultural entities operating within the nonMSA Oklahoma Assessment Area. Based on this
186
Arvest Bank
January 10, 2011
Total
Businesses
2,246
9,062
3,099
719
4,045
729
1,597
3,658
646
1,748
53
712
6,927
3,561
680
1,822
5,938
1,321
210
1,917
Industry
Construction
Information
Manufacturing
Mining
Retail Trade
Transportation
Utilities
Wholesale Trade
TOTAL
50,690
% of Total
4.4%
17.9%
6.1%
1.4%
8.0%
1.4%
3.2%
7.2%
1.3%
3.4%
0.1%
1.4%
13.7%
7.0%
1.3%
3.6%
11.7%
2.6%
0.4%
3.8%
100%
administrative, support, waste and removal services; retail trade; and other services. The annual
unemployment rates in the assessment area varied significantly by county. The lowest 2008
average annual unemployment rate was 2.3 percent (Kingfisher County), and the highest
unemployment rate was 6.5 percent (McCurtain County). In 2009, 3.9 percent was the lowest
average annual unemployment rate (Grant County), and the highest rate was 10.7 percent
(Latimer County). In comparison, the average annual unemployment rates for the state of
Oklahoma were 3.7 percent in 2008 and 6.6 percent in 2009.55
55
187
Arvest Bank
January 10, 2011
According to community contacts, the rural areas of Oklahoma have stable economies and
sufficient access to financial services. The primary credit needs in rural Oklahoma relate to
housing and agricultural activities. The state, as a whole, has experienced approximately 7
percent population growth in the last ten years. In light of the multiple large cities in the state,
many rural areas have become bedroom communities, where people reside while seeking
employment in the larger cities.
Overall, initiatives supporting rural development are key to sustaining the economy of nonMSA
Oklahoma. Community contacts stated that many banks in the state participate in businesscooperative programs, as well as other programs supporting rural housing development and
utilities assistance. Among the rural housing needs are direct loans, housing rehabilitation loans
and grants, and technical assistance grants for low-income individuals. One challenge facing the
area is finding credit for low-income applicants with poor credit history; additional bank
assistance for these individuals would be welcomed, particularly as related to specialized credit
products and financial education.
188
Arvest Bank
January 10, 2011
CONCLUSIONS
WITH
RESPECT
NONMETROPOLITAN OKLAHOMA
TO
PERFORMANCE
TESTS
IN
LENDING TEST
Lending levels reflect good responsiveness to nonMSA Oklahoma Assessment Area credit
and businesses/farms of different sizes. Lastly, the bank makes a relatively high level of
community development loans in the nonMSA Oklahoma Assessment Area.
Lending Activity
The bank‟s lending levels within the nonMSA Oklahoma Assessment Area reflect good
Loan Type
#
%
$(000s)
%
Home Improvement
669
10.3%
$20,439
5.9%
Home Purchase
143
2.2%
$7,319
2.1%
8
0.1%
$7,884
2.3%
700
10.8%
$41,747
12.0%
Total HMDA related
1,520
23.4%
$77,389
22.2%
Small Business
2,753
42.5%
$186,032
53.5%
Small Farm
2,211
34.1%
$84,561
24.3%
6,484
100%
$347,982
100%
Refinancing
TOTAL LOANS
189
Arvest Bank
January 10, 2011
As noted in the Description of Institution’s Operations in nonMSA Oklahoma section, this
assessment area includes one low-income census tract and 50 moderate-income census tracts,
representing 17.5 percent of all assessment area geographies. Overall, based on lending activity
from all three loan categories reviewed, the geographic distribution of loans reflects adequate
penetration throughout the assessment area. The following table displays the geographic
distribution of HMDA loans in comparison to owner-occupied housing demographics for the
assessment area
Dataset
Home Purchase
Refinance
Home
Improvement
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
62
297
159
0
12.0%
57.3%
30.7%
119
698
239
11.3%
66.1%
22.6%
29
198
68
9.8%
67.1%
23.1%
2
4
1
28.6%
57.1%
14.3%
212
1,197
467
0.0%
11.3%
63.8%
24.9%
0.0%
100%
0.0%
13.1%
70.8%
16.0%
0.0%
100%
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
518
100%
1,056
100%
295
100%
7
Multi-Family
0.0%
TOTAL
LOANS
Owner Occupied
Housing
0
0.0%
0
100%
1,876
The analysis of the bank‟s 2009 HMDA-lending activity revealed that lending in moderateincome census tracts is good (residential real estate lending opportunity in the only low-income
census tract is de minimis). As displayed in the preceding table, 11.3 percent of the bank‟s loans
were made in moderate-income census tracts, which is slightly below the percentage of owneroccupied housing units in moderate-income census tracts, 13.1 percent, but greater than 2009
HMDA aggregate lending level, 9.4 percent.
190
Arvest Bank
January 10, 2011
displayed in the following table compared to the distribution of assessment area businesses by
geography income level.
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
1
229
979
294
0
15.2%
65.1%
19.6%
17.7%
65.1%
16.7%
0.1%
0.6%
0.0%
0.0%
TOTAL
1,503
100%
100%
While the bank had a very small percentage of small business loans in the one low-income
census tract (0.1 percent), business lending opportunities in this geography appear to be minimal.
The level of small business loans within moderate-income census tracts (15.2 percent) is below
but within adequate range of the percentage of businesses within moderate-income census tracts
(17.7 percent) and the 2009 CRA aggregate lending level in moderate-income census tracts (16.1
percent). Therefore, the analysis of small business loans reflects adequate penetration throughout
the assessment area.
comparison to the distribution of assessment area farms by geography income level.
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
76
914
76
0
7.1%
85.7%
7.1%
10.6%
76.1%
13.4%
0.0%
0.0%
0.0%
0.0%
TOTAL
1,066
100%
100%
While below data used for comparison, the bank‟s level of small farm loans made in moderateincome census tracts is adequate (there are no small farms within the only low-income
assessment area geography). As displayed in the preceding table, the bank‟s level of small farm
loans made within moderate-income census tracts (7.1 percent) is below but within an adequate
range of the estimated percentage of farms located in moderate-income census tracts (10.6
percent). Therefore, the geographic distribution of the bank‟s small farm loans is adequate.
191
Arvest Bank
January 10, 2011
demographics.
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
50
122
135
202
9
9.7%
23.6%
26.1%
39.0%
1.7%
100%
65
158
228
592
13
1,056
6.2%
15.0%
21.6%
56.1%
1.2%
100%
63
61
120
26
21.4%
20.7%
40.7%
8.8%
0
0
0
25
8.5%
0
518
295
100%
7
7
100.0%
100%
0.0%
0.0%
0.0%
0.0%
140
343
424
914
55
1,876
7.5%
18.3%
22.6%
48.7%
2.9%
100%
20.6%
18.2%
21.5%
39.6%
0.0%
100%
As displayed in the preceding table, the bank‟s level of lending to low-income borrowers (7.5
percent) is below the low-income family population (20.6 percent); nevertheless, the bank‟s
performance is good compared to the 2009 HMDA aggregate lending level to low-income
borrowers (5.6 percent). Furthermore, the bank‟s lending level to moderate-income borrowers
(18.3 percent) is above the percentage of moderate-income borrowers within the assessment area
(18.2 percent) and it is above the aggregate lending level to moderate-income borrowers (15.1
percent). Therefore, the bank‟s level of lending to LMI borrowers within the assessment area is
excellent.
192
Arvest Bank
January 10, 2011
Next, small business loans were reviewed to determine the bank‟s lending level to businesses of
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>100<$250
>$250 <$1,000
1,253
102
53
1,408
84.0%
6.8%
3.6%
94.4%
36
16
31
83
2.4%
1.1%
2.1%
5.6%
1,289
118
84
1,491
86.5%
7.9%
5.6%
100%
majority of its small business loans (94.4 percent) to businesses with gross annual revenues of $1
million or less. The highest concentration of these loans was for loan amounts of $100,000 or
less, which further demonstrates the bank‟s willingness to make credit available to small
businesses in the assessment area. According to Dun & Bradstreet estimates, 89.5 percent of
businesses reporting for 2009 had revenues of $1 million or less. In addition, the bank‟s level of
lending to small businesses significantly exceeds the 2009 CRA aggregate lending level of 23.7
percent.
56
This analysis included 1,503 small business loans; however, 12 of these loans were removed from the sample
193
Arvest Bank
January 10, 2011
Small farm lending performance was analyzed by the revenue size of the farm and by the dollar
amount of the loan. The following table shows the distribution of small farm loans by loan
amount and farm revenue size.
Gross Revenue
$1 Million or Less
Greater Than $1
Million
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
973
69
20
1,062
91.3%
6.5%
1.9%
99.6%
2
2
0
4
0.2%
0.2%
0.0%
0.4%
975
71
20
1,066
91.5%
6.7%
1.9%
100%
The bank‟s level of lending to small farms is excellent. All but four of the bank‟s small farm
loans (99.6 percent) made in this assessment area were originated to farmers with gross annual
revenues of $1 million or less. Additionally, the largest concentration of these loans was in loan
available to small farms in the assessment area. According to Dun & Bradstreet estimates, 98.5
percent of farms in the assessment area reported revenues of $1 million or less. Furthermore, the
bank‟s performance is above that of other lenders based on 2009 CRA aggregate data, which
indicate a small farm lending level of 90.9 percent.
Arvest Bank makes a relatively high level of community development loans in the nonMSA
Oklahoma assessment area. During the review period, the bank originated nine community
development loans totaling $12.8 million within this assessment area. Two loans were for
affordable housing projects and two loans were made to organizations that provide community
services to LMI individuals. Four loans were for revitalization/stabilization projects in LMI
geographies. The remaining loan promoted economic development by providing permanent job
creation for LMI individuals.
194
Arvest Bank
January 10, 2011
INVESTMENT TEST
Arvest Bank has an excellent level of qualified community development investments and grants
within the nonMSA Oklahoma Assessment Area, exhibiting excellent responsiveness to credit
and community development needs in the assessment area. As of this evaluation date, the bank
had a community development investment balance of $10.7 million attributable to this
assessment area, representing an increase of $2.1 million (24.4 percent) since the last CRA
evaluation. The bank had qualified investments in MBS that finance affordable housing made in
a previous review period still outstanding of $2.1 million. Further, during this review period, the
bank invested $8.6 million in a tax credit equity fund that provides affordable housing for lowincome families. Additionally, Arvest Bank made an excellent level of qualified community
development grants within the assessment area. The bank made 273 qualified grants totaling
$343,729 during this review period. Among the numerous qualifying contributions were
significant donations to schools with a large majority of students from LMI families, affordable
housing organizations, food banks serving the homeless, and community service organizations
targeting the needs of LMI families.
195
Arvest Bank
January 10, 2011
SERVICE TEST
Arvest Bank‟s service delivery systems are readily accessible to the nonMSA Oklahoma
Assessment Area, and the bank‟s record of opening and closing branches improved the
accessibility of its delivery systems to LMI geographies and/or LMI individuals. Business hours
and services do not vary in a way that inconveniences LMI geographies and/or LMI individuals.
Lastly, the bank provides an adequate level of community development services in the nonMSA
Oklahoma Assessment Area.
Arvest Bank operates 32 branch facilities within the nonMSA Oklahoma Assessment Area. The
Dataset
Branches
1
5
21
5
0
3.1%
15.6%
65.6%
15.6%
0.0%
TOTAL
32
100%
Census Tracts
0.3%
17.2%
70.8%
11.7%
0.0%
100%
Household
Population
0.5%
15.4%
68.4%
15.8%
0.0%
100%
As illustrated in the table above, 18.7 percent of Arvest Bank‟s nonMSA Oklahoma Assessment
Area branches are located in LMI census tracts, which are greater than the percentage of
households in LMI census tracts, 15.9 percent. Based on this information, Arvest Bank‟s
delivery systems are readily accessible to geographies and individuals of different income levels
in the nonMSA Oklahoma Assessment Area.
During the review period, the bank opened two branches in this assessment area, one in a lowincome census tract and one in an upper-income census tract. Consequently the bank‟s record of
opening and closing branches in the nonMSA Oklahoma Assessment Area improved the
accessibility of its delivery systems, particularly to LMI geographies and/or LMI individuals.
196
Arvest Bank
January 10, 2011
the nonMSA Oklahoma Assessment Area. Most branches have Saturday operating hours and
offer extended hours of operations in their lobby and drive-up facilities at some point during the
week. Most drive-thru facilities remain open until 6 p.m., Monday through Friday, and are open
until noon on Saturdays. All branches offer the same standard products, including low-cost
checking and savings accounts, certificates of deposit, real estate and consumer loans, and other
services. Therefore, bank services do not vary in a way that inconveniences certain segments of
this assessment area, particularly LMI geographies and/or LMI individuals.
Arvest Bank personnel provides an adequate level of community development services in the
nonMSA Oklahoma Assessment Area. Throughout the review period, three bank employees
provided community development services to four separate organizations. Two of these
organizations assist schools with a majority of students from LMI families, and two
organizations work towards revitalization and stabilization of LMI areas.
197
Arvest Bank
January 10, 2011
Appendix A
SCOPE OF EXAMINATION TABLES
TIME PERIOD
REVIEWED
1/1/2008 TO 12/31/2009 (HMDA, small business, and small farm
data)
7/1/2008 TO 1/10/2011 (community development loans,
investment, and service activities)
FINANCIAL
INSTITUTION
PRODUCTS
REVIEWED
Arvest Bank
AFFILIATE(S)
HMDA
Small Business
Small Farm
AFFILIATE
RELATIONSHIP
PRODUCTS
REVIEWED
Arvest Mortgage
Company
Bank subsidiary
Mortgage Loans
Security BankCard
Center
Bank subsidiary
Small Business Credit
Cards
198
Arvest Bank
January 10, 2011
Appendix A (continued)
Assessment Area
Fayetteville-SpringdaleRogers, AR-MO MSA
Fort Smith, AR-MO MSA
Kansas City, MO-KS MSA
State
ARMO
AROK
MOKS
MSA
# of
Offices
% of
Offices
Branches CRA Review
Visited
Procedures
MSA
52
21.8%
0
Full Scope
MSA
17
7.1%
0
Full Scope
MSA
10
4.2%
2
Full Scope
Little Rock-North Little
Rock-Conway, AR MSA
AR
MSA
24
10.0%
0
Full Scope
Hot Springs, AR MSA
AR
MSA
3
1.3%
1
Limited
Scope
NonMSA AR
AR
non
21
8.8%
1
Full Scope
NonMSA KS
KS
non
1
0.4%
0
Full Scope
Joplin, MO MSA
MO
MSA
10
4.2%
0
Springfield, MO MSA
MO
MSA
4
1.7%
2
NonMSA MO
MO
non
4
1.7%
0
Full Scope
Lawton, OK MSA
OK
MSA
5
2.1%
0
Full Scope
Tulsa, OK MSA
OK
MSA
29
12.1%
1
Full Scope
Oklahoma City, OK MSA
OK
MSA
27
11.3%
0
Limited
Scope
NonMSA OK
OK
non
32
13.4%
1
Full Scope
N/A
N/A
239
100%
8
10 Full
Scope
Overall Bank
199
Limited
Scope
Limited
Scope
Arvest Bank
January 10, 2011
Appendix B
SUMMARY OF STATE AND MULTISTATE MSA RATINGS
State or Multistate
MSA Name
Fayetteville AR-MO
MSA
Fort Smith AR-OK
MSA
Kansas City KS-MO
MSA
Arkansas
Kansas
Missouri
Oklahoma
Lending Test
Rating
High
Satisfactory
Low
Satisfactory
High
Satisfactory
High
Satisfactory
High
Satisfactory
High
Satisfactory
High
Satisfactory
Investment
Test Rating
Outstanding
Low
Satisfactory
Low
Satisfactory
High
Satisfactory
Needs to
Improve
Low
Satisfactory
High
Satisfactory
200
Service Test
Rating
Low
Satisfactory
High
Satisfactory
Low
Satisfactory
Low
Satisfactory
Low
Satisfactory
Low
Satisfactory
Low
Satisfactory
Overall
Rating
Satisfactory
Satisfactory
Satisfactory
Satisfactory
Satisfactory
Satisfactory
Satisfactory
Arvest Bank
January 10, 2011
Appendix C
2009 LENDING PERFORMANCE TABLES FOR LIMITED-SCOPE REVIEW AREAS
ARKANSAS
Hot Springs, Arkansas MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
2
33
4
0
84.6%
10.3%
43
6
82.7%
11.5%
4
25
7
11.1%
69.4%
19.4%
0
5
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
5.1%
3
5.8%
0.0%
9
100%
0.0%
106
17
0.0%
0
0.0%
0
0.0%
TOTAL
39
100%
52
100%
36
100%
0
0.0%
0
5
100%
132
0.0%
6.8%
80.3%
12.9%
0.0%
100%
0.0%
15.1%
71.4%
13.5%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
29
72
9
0
26.4%
65.5%
8.2%
27.5%
59.7%
12.7%
0.0%
0.0%
201
0.0%
0.0%
TOTAL
110
100%
100%
Arvest Bank
January 10, 2011
Appendix C (continued)
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
8.3%
85.0%
6.7%
0.0%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
0
10
10
19
0
25.6%
25.6%
48.7%
5
9
32
17.3%
61.5%
5
8
21
13.9%
22.2%
58.3%
0
0
0
0.0%
5
9.6%
2
5.6%
0
0.0%
9.6%
0.0%
0.0%
0.0%
20
27
72
5.3%
15.2%
20.5%
54.5%
19.0%
18.1%
23.1%
39.9%
7
202
0.0%
1
1.9%
0
0.0%
TOTAL
39
100%
52
100%
36
100%
5
5
100%
100%
6
132
4.5%
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
>100<250
>250 <1,000
81
9
9
99
75.0%
8.3%
8.3%
91.7%
6
2
1
9
5.6%
1.9%
0.9%
8.3%
87
11
10
108
80.6%
10.2%
9.3%
100%
TOTAL
TOTAL
<$100
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250 >$250<$500
TOTAL
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
203
Arvest Bank
January 10, 2011
MISSOURI
Joplin, Missouri MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
12
157
18
0
6.4%
84.0%
9.6%
11
298
25
3.3%
89.2%
7.5%
0.0%
0
0.0%
0
0.0%
0
0.0%
4
8.5%
37
6
78.7%
12.8%
5
0
0
0.0%
0
0.0%
0
0.0%
TOTAL
187
100%
334
100%
47
100%
0
0.0%
100%
0.0%
27
497
49
0.0%
4.7%
86.7%
8.6%
0.0%
100%
0.0%
8.1%
84.2%
7.7%
0.0%
100%
0
0.0%
5
0
100%
573
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
45
177
24
0
18.3%
72.0%
9.8%
14.5%
78.2%
0.0%
0.0%
204
7.3%
0.0%
0.0%
TOTAL
246
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
38
1
0
0.0%
0.0%
0.0%
0.8%
97.4%
97.8%
2.6%
1.4%
0.0%
0.0%
TOTAL
39
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
21
49
45
70
2
11.2%
26.2%
24.1%
37.4%
18
52
80
183
15.6%
24.0%
54.8%
5
12
25
10.6%
25.5%
53.2%
0
0
0
5.4%
3
6.4%
0
1.1%
1
0.3%
2
4.3%
187
100%
334
100%
47
100%
5
5
100%
100%
573
0.0%
0.0%
0.0%
0.0%
42
106
137
278
10
7.3%
18.5%
23.9%
48.5%
1.7%
17.4%
19.4%
24.6%
38.6%
205
TOTAL
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
144
38
27
209
58.8%
15.5%
11.0%
85.3%
13
11
12
36
5.3%
4.5%
4.9%
14.7%
157
49
39
245
64.1%
20.0%
15.9%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
37
2
0
39
94.9%
5.1%
0.0%
100.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
37
2
0
39
94.9%
5.1%
0.0%
100%
206
Arvest Bank
January 10, 2011
Springfield, Missouri MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
6
39
24
0
56.5%
34.8%
51
39
53.7%
41.1%
4
2
66.7%
33.3%
0
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
8.7%
5
5.3%
0
0.0%
1
100%
12
0.0%
0.0%
94
65
0.0%
0
0.0%
TOTAL
69
100%
95
100%
0
0.0%
6
100%
0
0.0%
0
1
100%
171
0.0%
7.0%
55.0%
38.0%
0.0%
100%
0.0%
16.2%
56.8%
27.0%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
7
21
25
0
13.2%
39.6%
47.2%
16.5%
54.3%
27.0%
0.0%
2.3%
207
0.0%
0.0%
TOTAL
53
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
2
0
0
0.0%
0.3%
0.0%
13.9%
100.0%
72.6%
0.0%
13.2%
0.0%
0.0%
TOTAL
2
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
13
17
22
17
0
18.8%
24.6%
31.9%
24.6%
4
20
29
41
21.1%
30.5%
43.2%
0
0
6
4.2%
0
0.0%
0
0.0%
0.0%
0
0
100%
0
0.0%
0.0%
0.0%
0.0%
17
37
51
64
9.9%
21.6%
29.8%
37.4%
17.4%
19.6%
24.1%
38.9%
208
0.0%
1
1.1%
0
0.0%
TOTAL
69
100%
95
100%
6
100%
1
1
100%
100%
2
171
1.2%
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
19
21
7
47
36.5%
40.4%
13.5%
90.4%
2
1
2
5
3.8%
1.9%
3.8%
9.6%
21
22
9
52
40.4%
42.3%
17.3%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250 <$500
1
0
1
2
50.0%
0.0%
50.0%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
1
0
1
2
50.0%
0.0%
50.0%
100%
209
Arvest Bank
January 10, 2011
OKLAHOMA
Oklahoma City, Oklahoma MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
6
62
203
218
0
12.7%
41.5%
44.6%
57
275
375
8.0%
38.6%
52.7%
27
80
114
12.2%
36.0%
51.4%
1
1
0
0.0%
50.0%
50.0%
0.0%
11
147
559
707
0.8%
10.3%
39.2%
49.6%
0.1%
100%
1.8%
21.8%
41.2%
35.2%
0.0%
100%
1.2%
4
0.6%
1
0.5%
0
0.0%
1
0.1%
0
0.0%
489
100%
712
100%
222
100%
0
0.0%
1
2
100%
1,425
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
22
136
193
190
12
4.0%
24.6%
34.9%
34.4%
2.2%
22.6%
38.0%
33.4%
4.1%
210
1.9%
TOTAL
553
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
1
7
18
5
3
20.6%
52.9%
14.7%
17.3%
51.4%
30.5%
2.9%
0.6%
8.8%
0.3%
TOTAL
34
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
66
141
131
143
8
13.5%
28.8%
26.8%
29.2%
36
102
163
407
5.1%
14.3%
22.9%
57.2%
28
46
129
12.6%
20.7%
58.1%
0
0
0
18
8.1%
0
1.6%
4
0.6%
1
0.5%
TOTAL
489
100%
712
100%
222
100%
2
2
100%
100%
0.0%
0.0%
0.0%
0.0%
120
271
340
679
15
1,425
8.4%
19.0%
23.9%
47.6%
1.1%
100%
20.0%
18.2%
21.7%
40.1%
211
0.0%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
353
43
32
428
64.3%
7.8%
5.8%
78.0%
74
20
27
121
13.5%
3.6%
4.9%
22.0%
427
63
59
549
77.8%
11.5%
10.7%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
30
2
2
34
88.2%
5.9%
5.9%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
30
2
2
34
88.2%
5.9%
5.9%
100%
212
Arvest Bank
January 10, 2011
Appendix D
2008 LENDING PERFORMANCE TABLES
Fayetteville-Springdale-Rogers, Arkansas and Missouri MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
4
47
1,046
289
0
3.4%
75.5%
20.9%
183
2,515
691
5.4%
74.1%
20.4%
57
1,094
301
3.9%
75.3%
20.7%
3
0
0.3%
5
0.1%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
TOTAL
1,386
100%
3,394
100%
1,452
100%
0
0.0%
100%
0.0%
287
4,658
1,281
0.1%
4.6%
74.7%
20.5%
0.0%
100%
0.2%
11.7%
71.9%
16.2%
0.0%
100%
9
0.0%
3
0
100%
6,235
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
10
350
1,992
608
0
0.3%
11.8%
67.3%
20.5%
15.1%
65.8%
18.3%
0.8%
213
0.0%
0.0%
TOTAL
2,960
100%
100%
Arvest Bank
January 10, 2011
Appendix D (continued)
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
1
127
602
33
0
16.6%
78.9%
4.3%
20.9%
72.7%
0.1%
0.0%
6.4%
0.0%
0.0%
TOTAL
763
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
86
273
325
668
34
1,386
6.2%
19.7%
23.4%
48.2%
2.5%
100%
221
474
663
1,789
247
3,394
6.5%
14.0%
19.5%
52.7%
7.3%
100%
65
145
238
747
257
1,452
4.5%
10.0%
16.4%
51.4%
17.7%
100%
0
0
0
3
3
100%
100%
0
0.0%
0.0%
0.0%
0.0%
372
892
1,226
3,204
541
6,235
6.0%
14.3%
19.7%
51.4%
8.7%
100%
18.5%
18.7%
24.0%
38.8%
214
0.0%
100%
Arvest Bank
January 10, 2011
Gross Revenue
<$100
$1 Million or Less
>$100<$250 >$250 <$1,000
TOTAL
2,156
413
308
2,877
72.9%
14.0%
10.4%
97.3%
7
2
72
81
0.2%
0.1%
2.4%
2.7%
2,163
415
380
2,958
73.1%
14.0%
12.8%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
659
74
30
763
86.4%
9.7%
3.9%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
659
74
30
763
86.4%
9.7%
3.9%
100%
215
Arvest Bank
January 10, 2011
Fort Smith, Arkansas and Oklahoma MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
17
341
86
0
3.8%
76.8%
19.4%
18
466
109
3.0%
78.6%
18.4%
228
67
76.0%
22.3%
0.0%
0
0.0%
0
0.0%
5
1.7%
0.0%
0
0.0%
0
0.0%
TOTAL
444
100%
593
100%
300
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
40
1,035
262
0
1,337
0.0%
3.0%
77.4%
19.6%
0.0%
100%
0.0%
3.5%
84.0%
12.5%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
33
337
207
0
5.7%
58.4%
35.9%
75.2%
16.1%
0.0%
0.0%
8.7%
216
0.0%
0.0%
TOTAL
577
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
39
9
0
81.3%
18.8%
92.1%
6.9%
0.0%
0.0%
0.0%
0.9%
0.0%
0.0%
TOTAL
48
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
30
92
113
157
52
444
6.8%
20.7%
25.5%
35.4%
11.7%
100%
48
114
111
298
22
593
8.1%
19.2%
18.7%
50.3%
3.7%
44
61
157
26
14.7%
20.3%
52.3%
8.7%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
90
250
285
612
100
1,337
6.7%
18.7%
21.3%
45.8%
7.5%
100%
19.7%
17.9%
22.9%
39.5%
12
4.0%
217
0.0%
100%
300
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
<$100
$1 Million or Less
>$100<$250 >$250 <$1,000
TOTAL
446
80
40
566
77.3%
13.9%
6.9%
98.1%
0
1
10
11
0.0%
0.2%
1.7%
1.9%
446
81
50
577
77.3%
14.0%
8.7%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
36
4
8
48
75.0%
8.3%
16.7%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
36
4
8
48
75.0%
8.3%
16.7%
100%
218
Arvest Bank
January 10, 2011
Little Rock-North Little Rock-Conway, Arkansas MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
6
17
227
142
0
4.3%
57.9%
36.2%
40
280
154
8.4%
58.7%
32.3%
27
235
146
6.6%
57.2%
35.5%
1.5%
3
0.6%
3
0.7%
0.0%
0
0.0%
0
0.0%
TOTAL
392
100%
477
100%
411
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
12
84
742
442
0
1,280
0.9%
6.6%
58.0%
34.5%
0.0%
100%
1.5%
15.0%
55.4%
28.2%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
48
100
309
243
0
6.9%
14.3%
44.1%
34.7%
17.5%
51.3%
26.0%
5.3%
219
0.0%
0.0%
TOTAL
700
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
1
3
5
1
0
10.0%
30.0%
50.0%
10.0%
1.2%
17.7%
62.8%
18.2%
0.0%
0.0%
TOTAL
10
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
27
109
94
145
17
6.9%
27.8%
24.0%
37.0%
4.3%
90
109
221
23
18.9%
22.9%
46.3%
4.8%
50
100
204
24
12.2%
24.3%
49.6%
5.8%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
94
249
303
570
64
1,280
7.3%
19.5%
23.7%
44.5%
5.0%
100%
19.7%
18.1%
22.5%
39.7%
34
7.1%
33
8.0%
220
0.0%
392
100%
477
100%
411
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
511
97
68
676
73.0%
13.9%
9.7%
96.6%
1
3
20
24
0.1%
0.4%
2.9%
3.4%
512
100
88
700
73.1%
14.3%
12.6%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250 >$250<$500
TOTAL
5
3
2
10
50.0%
30.0%
20.0%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
5
3
2
10
50.0%
30.0%
20.0%
100%
221
Arvest Bank
January 10, 2011
Hot Springs, Arkansas MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
1
27
1
0
0.0%
0
3.4%
93.1%
3.4%
0.0%
29
100%
6
28
8
14.3%
66.7%
19.0%
11
43
10
17.2%
67.2%
15.6%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
18
98
19
0
135
0.0%
13.3%
72.6%
14.1%
0.0%
100%
0.0%
15.1%
71.4%
13.5%
0.0%
100%
0.0%
0
0.0%
0
TOTAL
0.0%
0
0.0%
42
100%
64
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
22
79
9
0
20.0%
71.8%
8.2%
27.5%
59.7%
12.7%
0.0%
0.0%
222
0.0%
0.0%
TOTAL
110
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
8.3%
85.0%
6.7%
0.0%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
3
4
7
14
1
10.3%
13.8%
24.1%
48.3%
2
7
9
22
16.7%
21.4%
52.4%
9
18
26
14.1%
28.1%
40.6%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
11
20
34
62
8
135
8.1%
14.8%
25.2%
45.9%
19.0%
18.1%
23.1%
39.9%
4.8%
6
9.4%
223
3.4%
2
4.8%
5
7.8%
5.9%
0.0%
29
100%
42
100%
64
100%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
93
9
8
110
84.5%
8.2%
7.3%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
93
9
8
110
84.5%
8.2%
7.3%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250 >$250<$500
TOTAL
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
224
Arvest Bank
January 10, 2011
Nonmetropolitan Arkansas Statewide Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
1
277
57
0
82.7%
17.0%
601
55
91.3%
8.4%
235
29
88.7%
10.9%
1
0
0.0%
0
0.0%
0
0.0%
0
0.0%
0
0.3%
2
0.3%
1
0.4%
0
0.0%
4
100%
0.0%
1,114
141
0.0%
0
0.0%
0
0.0%
TOTAL
335
100%
658
100%
265
100%
0
0.0%
0
1
100%
1,259
0.0%
0.3%
88.5%
11.2%
0.0%
100%
0.0%
2.4%
87.4%
10.3%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
4
916
79
0
91.7%
7.9%
87.6%
10.7%
0.0%
0.0%
0.4%
1.7%
225
0.0%
0.0%
TOTAL
999
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
7
327
33
0
89.1%
9.0%
0.0%
0.0%
1.9%
1.5%
89.8%
8.8%
0.0%
0.0%
TOTAL
367
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
22
66
89
151
7
6.6%
19.7%
26.6%
45.1%
2.1%
58
104
160
306
30
8.8%
15.8%
24.3%
46.5%
4.6%
37
54
125
26
14.0%
20.4%
47.2%
9.8%
0
0
0
23
8.7%
0
TOTAL
335
100%
658
100%
265
100%
1
1
100%
100%
0.0%
0.0%
0.0%
0.0%
103
207
303
582
64
1,259
8.2%
16.4%
24.1%
46.2%
5.1%
100%
18.1%
18.7%
23.1%
40.1%
226
0.0%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
789
125
62
976
79.0%
12.5%
6.2%
97.7%
4
3
16
23
0.4%
0.3%
1.6%
2.3%
793
128
78
999
79.4%
12.8%
7.8%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
318
32
17
367
86.6%
8.7%
4.6%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
318
32
17
367
86.6%
8.7%
4.6%
100%
227
Arvest Bank
January 10, 2011
Nonmetropolitan Kansas Statewide Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
1
7
0
0
12.5%
87.5%
2
16
11.1%
88.9%
1
13
0.0%
0
0.0%
0
0.0%
7.1%
92.9%
0.0%
0
0.0%
0
0.0%
0.0%
0
0.0%
0
0.0%
TOTAL
8
100%
18
100%
14
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
4
36
0
0
40
0.0%
10.0%
90.0%
0.0%
0.0%
100%
0.0%
13.9%
82.9%
3.2%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
5
94
0
0
0.0%
0.0%
5.1%
94.9%
19.6%
77.2%
228
0.0%
3.2%
0.0%
0.0%
TOTAL
99
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
2
65
0
0
0.0%
0.0%
3.0%
4.1%
97.0%
94.4%
0.0%
1.4%
0.0%
0.0%
TOTAL
67
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
2
3
0
3
0
25.0%
37.5%
3
2
6
6
16.7%
11.1%
33.3%
33.3%
0
3
5
4
2
14
21.4%
35.7%
28.6%
14.3%
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
5
8
11
13
3
40
12.5%
20.0%
27.5%
32.5%
20.3%
20.8%
25.0%
33.8%
0.0%
0.0%
229
37.5%
0.0%
1
5.6%
7.5%
0.0%
8
100%
18
100%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
84
10
2
96
84.8%
10.1%
2.0%
97.0%
0
0
3
3
0.0%
0.0%
3.0%
3.0%
84
10
5
99
84.8%
10.1%
5.1%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
65
2
0
67
97.0%
3.0%
0.0%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
65
2
0
67
97.0%
3.0%
0.0%
100%
230
Arvest Bank
January 10, 2011
Joplin, Missouri MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
9
122
15
0
83.6%
10.3%
155
35
78.3%
17.7%
116
12
84.7%
8.8%
0.0%
0
0.0%
0
0.0%
0
0.0%
0
6.2%
8
4.0%
9
6.6%
0
0.0%
2
100.0%
0
0.0%
0.0%
0
0.0%
0
0.0%
TOTAL
146
100%
198
100%
137
100%
0
0.0%
0
2
100%
26
395
62
0.0%
5.4%
81.8%
12.8%
0.0%
100%
0.0%
8.1%
84.2%
7.7%
0.0%
100%
483
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
56
221
31
0
18.2%
71.8%
10.1%
14.5%
78.2%
7.3%
0.0%
0.0%
231
0.0%
0.0%
TOTAL
308
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
45
2
0
0.0%
0.0%
0.0%
0.8%
95.7%
97.8%
4.3%
1.4%
0.0%
0.0%
TOTAL
47
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
14
33
37
56
6
22.6%
25.3%
38.4%
4.1%
24
38
113
18
12.1%
19.2%
57.1%
9.1%
18
23
78
13.1%
16.8%
56.9%
0
0
0
9.6%
5
2.5%
7
5.1%
0
11
8.0%
146
100%
198
100%
137
100%
2
2
100%
100%
483
0.0%
0.0%
0.0%
0.0%
26
75
98
247
37
5.4%
15.5%
20.3%
51.1%
7.7%
17.4%
19.4%
24.6%
38.6%
232
TOTAL
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
194
59
42
295
63.0%
19.2%
13.6%
95.8%
2
0
11
13
0.6%
0.0%
3.6%
4.2%
196
59
53
308
63.6%
19.2%
17.2%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
40
4
3
47
85.1%
8.5%
6.4%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
40
4
3
47
85.1%
8.5%
6.4%
100%
233
Arvest Bank
January 10, 2011
Springfield, Missouri MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
5
17
9
0
16.1%
54.8%
29.0%
1
14
19
41.2%
55.9%
0
13
0.0%
0
0.0%
0
0.0%
2.9%
1
7.1%
0.0%
92.9%
0.0%
0
0.0%
0
0.0%
TOTAL
31
100%
34
100%
14
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
7
31
41
0
79
0.0%
8.9%
39.2%
51.9%
0.0%
100%
0.0%
16.2%
56.8%
27.0%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
6
23
15
0
13.6%
52.3%
34.1%
16.5%
54.3%
27.0%
0.0%
2.3%
234
0.0%
0.0%
TOTAL
44
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.3%
13.9%
72.6%
13.2%
0.0%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
1
7
11
11
1
22.6%
35.5%
35.5%
5
7
20
14.7%
20.6%
58.8%
0
2
9
3
14
14.3%
64.3%
21.4%
100%
3.2%
2
5.9%
0
0.0%
0.0%
3.2%
0
0.0%
31
100%
34
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
3
12
20
40
4
79
3.8%
15.2%
25.3%
50.6%
17.4%
19.6%
24.1%
38.9%
235
5.1%
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
21
10
9
40
47.7%
22.7%
20.5%
90.9%
0
0
4
4
0.0%
0.0%
9.1%
9.1%
21
10
13
44
47.7%
22.7%
29.5%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
236
Arvest Bank
January 10, 2011
Nonmetropolitan Missouri Statewide Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
56
0
0
0.0%
0
0.0%
0
0.0%
0.0%
0
0.0%
0
0.0%
100.0%
110
100.0%
41
100.0%
0.0%
0
0.0%
0
0.0%
0.0%
0
0.0%
0
0.0%
TOTAL
56
100%
110
100%
41
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0
0
207
0
0
207
0.0%
0.0%
100.0%
0.0%
0.0%
100%
0.0%
1.8%
98.2%
0.0%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
100
0
0
0.0%
0.0%
0.0%
0.2%
100.0%
99.8%
237
0.0%
0.0%
0.0%
0.0%
TOTAL
100
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
0
16
0
0
0.0%
0.0%
0.0%
0.8%
100.0%
99.2%
0.0%
0.0%
0.0%
0.0%
TOTAL
16
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
3
11
18
22
2
19.6%
32.1%
39.3%
18
19
62
16.4%
17.3%
56.4%
1
6
24
7
41
14.6%
58.5%
17.1%
100%
5.4%
7
6.4%
3
7.3%
2.4%
3.6%
4
3.6%
56
100%
110
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
13
30
43
108
13
207
6.3%
14.5%
20.8%
52.2%
6.3%
18.6%
19.6%
24.7%
37.0%
238
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
67
18
12
97
67.0%
18.0%
12.0%
97.0%
0
0
3
3
0.0%
0.0%
3.0%
3.0%
67
18
15
100
67.0%
18.0%
15.0%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
15
0
1
16
93.8%
0.0%
6.3%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
15
0
1
16
93.8%
0.0%
6.3%
100%
239
Arvest Bank
January 10, 2011
Lawton, Oklahoma MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
0
5
25
11
0
12.2%
61.0%
26.8%
9
45
29
10.6%
52.9%
34.1%
2
33
18
62.3%
34.0%
0.0%
2
2.4%
0
0.0%
3.8%
0.0%
0
0.0%
0
0.0%
TOTAL
41
100%
85
100%
53
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
2
16
103
58
0
179
1.1%
8.9%
57.5%
32.4%
0.0%
100%
1.6%
15.8%
64.8%
17.9%
0.0%
100%
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
22
84
118
80
0
7.2%
27.6%
38.8%
26.3%
10.4%
29.2%
48.1%
12.3%
240
0.0%
0.0%
TOTAL
304
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
2
1
8
4
0
53.3%
26.7%
77.9%
14.2%
13.3%
0.5%
6.7%
7.4%
0.0%
0.0%
TOTAL
15
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
3
2
9
25
2
22.0%
61.0%
10
53
10
85
11.8%
62.4%
11.8%
100%
5
37
4
53
7.3%
4
4.7%
2
3.8%
4.9%
8
9.4%
5
9.4%
9.4%
69.8%
4.9%
7.5%
41
100%
100%
0
0
0
0
0
0
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
9
15
24
115
16
179
8.9%
5.0%
8.4%
13.4%
64.2%
20.5%
17.1%
22.2%
40.3%
241
0.0%
100%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
230
46
22
298
75.7%
15.1%
7.2%
98.0%
1
0
5
6
0.3%
0.0%
1.6%
2.0%
231
46
27
304
76.0%
15.1%
8.9%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
12
1
2
15
80.0%
6.7%
13.3%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
12
1
2
15
80.0%
6.7%
13.3%
100%
242
Arvest Bank
January 10, 2011
Tulsa, Oklahoma MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
4
42
181
227
0
9.3%
39.9%
50.0%
58
195
308
10.3%
34.6%
54.6%
68
230
282
11.7%
39.5%
48.5%
0
0
1
0.9%
3
0.5%
2
0.3%
0
0.0%
0.0%
0
0.0%
0
0.0%
TOTAL
454
100%
564
100%
582
100%
0
0.0%
0.0%
100%
168
606
818
0.6%
10.5%
37.9%
51.1%
0.0%
100%
0.9%
20.8%
47.4%
30.8%
0.0%
100%
9
0.0%
1
0
100%
1,601
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
4
212
458
776
0
14.6%
31.6%
53.5%
23.9%
41.6%
33.3%
0.3%
1.1%
243
0.0%
0.0%
TOTAL
1,450
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
14
84
23
0
11.6%
69.4%
19.0%
24.8%
57.0%
18.1%
0.0%
0.1%
0.0%
0.0%
TOTAL
121
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
32
90
126
193
13
19.8%
27.8%
42.5%
2.9%
71
98
302
59
564
12.6%
17.4%
53.5%
10.5%
100%
91
116
276
60
582
15.6%
19.9%
47.4%
10.3%
100%
0
0
0
1
1
7.0%
34
6.0%
39
6.7%
0
454
100%
0.0%
0.0%
0.0%
0.0%
100%
100%
105
252
340
771
133
1,601
6.6%
15.7%
21.2%
48.2%
8.3%
100%
19.9%
18.3%
21.6%
40.1%
244
0.0%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
1,086
181
145
1,412
74.9%
12.5%
10.0%
97.4%
3
1
34
38
0.2%
0.1%
2.3%
2.6%
1,089
182
179
1,450
75.1%
12.6%
12.3%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
98
14
9
121
81.0%
11.6%
7.4%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
98
14
9
121
81.0%
11.6%
7.4%
100%
245
Arvest Bank
January 10, 2011
Oklahoma City, Oklahoma MSA Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
4
44
150
162
0
12.2%
41.7%
45.0%
34
139
186
9.4%
38.5%
51.5%
25
134
176
7.4%
39.9%
52.4%
0
1
1.1%
2
0.6%
1
0.3%
0
0.0%
0
0.0%
0
0.0%
0
0.0%
TOTAL
360
100%
361
100%
336
100%
0
0.0%
0.0%
100%
103
423
525
0.7%
9.7%
40.0%
49.6%
0.0%
100%
1.8%
21.8%
41.2%
35.2%
0.0%
100%
7
0.0%
1
0
100%
1,058
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
28
138
255
224
21
4.2%
20.7%
38.3%
33.6%
3.2%
22.6%
38.0%
33.4%
4.1%
246
1.9%
TOTAL
666
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
1
7
15
3
3
29
24.1%
51.7%
10.3%
10.3%
100%
17.3%
51.4%
30.5%
0.3%
100%
3.4%
0.6%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
Low-
Moderate-
Middle-
Upper-
Unknown
22
100
79
157
2
6.1%
27.8%
21.9%
43.6%
0.6%
47
76
198
22
13.0%
21.1%
54.8%
6.1%
39
70
182
29
11.6%
20.8%
54.2%
8.6%
0
0
0
18
5.0%
16
4.8%
0
TOTAL
360
100%
361
100%
336
100%
1
1
100%
100%
0.0%
0.0%
0.0%
0.0%
56
186
225
537
54
1,058
5.3%
17.6%
21.3%
50.8%
5.1%
100%
20.0%
18.2%
21.7%
40.1%
247
0.0%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
512
79
54
645
77.0%
11.9%
8.1%
97.0%
6
4
10
20
0.9%
0.6%
1.5%
3.0%
518
83
64
665
77.9%
12.5%
9.6%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
21
3
5
29
72.4%
10.3%
17.2%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
21
3
5
29
72.4%
10.3%
17.2%
100%
248
Arvest Bank
January 10, 2011
Nonmetropolitan Oklahoma Statewide Assessment Area
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Owner Occupied
Housing
Low-
Moderate-
Middle-
Upper-
Unknown
1
58
298
137
0
11.7%
60.3%
27.7%
94
471
141
13.3%
66.6%
19.9%
35
260
79
9.4%
69.5%
21.1%
0
0
0.2%
1
0.1%
0
0.0%
0
0.0%
2
1
100%
0.0%
0.0%
0.0%
0
0.0%
0
0.0%
TOTAL
494
100%
707
100%
374
100%
0
0.0%
0
1
100%
188
1,029
357
0.1%
11.9%
65.3%
22.7%
0.0%
100%
0.0%
13.1%
70.8%
16.0%
0.0%
100%
1,576
Dataset
Small Business
Loans
Business
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
208
1,108
327
0
12.7%
67.4%
19.9%
17.7%
65.1%
16.7%
0.0%
0.6%
249
0.0%
0.0%
TOTAL
1,643
100%
100%
Arvest Bank
January 10, 2011
Dataset
Small Farm
Loans
Agricultural
Institutions
Low-
Moderate-
Middle-
Upper-
Unknown
0
79
984
82
0
6.9%
85.9%
7.2%
10.6%
76.1%
13.4%
0.0%
0.0%
0.0%
0.0%
TOTAL
1,145
100%
100%
Dataset
Home Purchase
Refinance
Home
Improvement
Multi-Family
Loans
HMDA
TOTAL
Families
TOTAL
Low-
Moderate-
Middle-
Upper-
Unknown
27
96
135
220
16
5.5%
19.4%
27.3%
44.5%
3.2%
39
118
142
366
42
5.5%
16.7%
20.1%
51.8%
5.9%
47
64
191
47
374
12.6%
17.1%
51.1%
12.6%
100%
0
0
0
1
1
25
6.7%
0
494
100%
707
100%
0.0%
0.0%
0.0%
0.0%
100%
100%
91
261
341
777
106
1,576
5.8%
16.6%
21.6%
49.3%
6.7%
100%
20.6%
18.2%
21.5%
39.6%
250
0.0%
100%
Arvest Bank
January 10, 2011
Gross Revenue
$1 Million or Less
TOTAL
<$100
>$100<$250
>$250 <$1,000
1,383
174
70
1,627
84.2%
10.6%
4.3%
99.0%
2
2
12
16
0.1%
0.1%
0.7%
1.0%
1,385
176
82
1,643
84.3%
10.7%
5.0%
100%
TOTAL
Gross Revenue
$1 Million or Less
TOTAL
TOTAL
<$100
>$100<$250
>$250<$500
1,031
84
30
1,145
90.0%
7.3%
2.6%
100%
0
0
0
0
0.0%
0.0%
0.0%
0.0%
1,031
84
30
1,145
90.0%
7.3%
2.6%
100%
251
Appendix E
GLOSSARY
Aggregate lending: The number of loans originated and purchased by all reporting lenders in
specified income categories as a percentage of the aggregate number of loans originated and
purchased by all reporting lenders in the metropolitan area/assessment area.
Census tract: A small subdivision of metropolitan and other densely populated counties.
Census tract boundaries do not cross county lines; however, they may cross the boundaries of
metropolitan statistical areas. Census tracts usually have between 2,500 and 8,000 persons, and
their physical size varies widely depending upon population density. Census tracts are designed
to be homogeneous with respect to population characteristics, economic status, and living
conditions to allow for statistical comparisons.
Community development: All Agencies have adopted the following language. Affordable
housing (including multifamily rental housing) for low- or moderate-income individuals;
community services targeted to low- or moderate-income individuals; activities that promote
economic development by financing businesses or farms that meet the size eligibility standards
of the Small Business Administration‟s Development Company or Small Business Investment
Company programs (13 CFR 121.301) or have gross annual revenues of $1 million or less; or,
activities that revitalize or stabilize low- or moderate-income geographies.
Effective September 1, 2005, the Board of Governors of the Federal Reserve System, Office of
the Comptroller of the Currency, and the Federal Deposit Insurance Corporation have adopted
the following additional language as part of the revitalize or stabilize definition of community
development. Activities that revitalize or stabilize(i)
Low-or moderate-income geographies;
(ii)
Designated disaster areas; or
(iii) Distressed or underserved nonmetropolitan middle-income geographies
designated by the Board, Federal Deposit Insurance Corporation, and Office of
the Comptroller of the Currency, based ona. Rates of poverty, unemployment, and population loss; or
b. Population size, density, and dispersion. Activities that revitalize and
stabilize geographies designated based on population size, density, and
dispersion if they help to meet essential community needs, including needs
of low- and moderate-income individuals.
Consumer loan(s): A loan(s) to one or more individuals for household, family, or other personal
expenditures. A consumer loan does not include a home mortgage, small business, or small farm
loan. This definition includes the following categories: motor vehicle loans, credit card loans,
home equity loans, other secured consumer loans, and other unsecured consumer loans.
252
Appendix E (continued)
Family: Includes a householder and one or more other persons living in the same household who
are related to the householder by birth, marriage, or adoption. The number of family households
always equals the number of families; however, a family household may also include nonrelatives living with the family. Families are classified by type as either a married-couple family
or other family, which is further classified into „male householder‟ (a family with a male
householder and no wife present) or „female householder‟ (a family with a female householder
and no husband present).
Full-scope review: Performance under the Lending, Investment, and Service Tests is analyzed
considering performance context, quantitative factors (for example, geographic distribution,
borrower distribution, and total number and dollar amount of investments), and qualitative
factors (for example, innovativeness, complexity, and responsiveness).
Geography: A census tract delineated by the United States Bureau of the Census in the most
recent decennial census.
Home Mortgage Disclosure Act (HMDA): The statute that requires certain mortgage lenders
that do business or have banking offices in a metropolitan statistical area to file annual summary
reports of their mortgage lending activity. The reports include such data as the race, gender, and
the income of applicants, the amount of loan requested, and the disposition of the application (for
example, approved, denied, and withdrawn).
Home mortgage loans: Includes home purchase and home improvement loans as defined in the
HMDA regulation. This definition also includes multifamily (five or more families) dwelling
loans, loans for the purchase of manufactured homes and refinancing of home improvement and
home purchase loans.
Household: Includes all persons occupying a housing unit. Persons not living in households are
classified as living in group quarters. In 100 percent tabulations, the count of households always
equals the count of occupied housing units.
Housing Affordability Ratio: This ratio is calculated by dividing the median household income
by the median housing value. It represents the amount of single family, owner-occupied housing
that a dollar of income can purchase for the median household in the census tract. Values closer
to 100 percent indicate greater affordability.
Limited-scope review: Performance under the Lending, Investment, and Service Tests is
analyzed using only quantitative factors (for example, geographic distribution, borrower
distribution, total number and dollar amount of investments, and branch distribution).
253
Location Quotient (LQ): The LQ is an industry concentration measure where an LQ of 1 means
that the industry‟s share of local employment equals that industry‟s share of the comparison area
(e.g., an LQ of 1.15 means that an area is 15% more reliant on that industry than the state as a
whole).
Low-income: Individual income that is less than 50 percent of the area median income, or a
median family income that is less than 50 percent, in the case of a geography.
Market share: The number of loans originated and purchased by the institution as a percentage
of the aggregate number of loans originated and purchased by all reporting lenders in the
metropolitan area/assessment area.
Metropolitan area (MA): A metropolitan statistical area (MSA) or a metropolitan division
(MD) as defined by the Office of Management and Budget. An MSA is a core area containing at
least one urbanized area of 50,000 or more inhabitants, together with adjacent communities
having a high degree of economic and social integration with that core. An MD is a division of
an MSA based on specific criteria including commuting patterns. Only an MSA that has a
population of at least 2.5 million may be divided into MDs.
Middle-income: Individual income that is at least 80 percent and less than 120 percent of the
area median income, or a median family income that is at least 80 percent and less than 120
percent, in the case of a geography.
Moderate-income: Individual income that is at least 50 percent and less than 80 percent of the
area median income, or a median family income that is at least 50 percent and less than 80
percent, in the case of a geography.
Multifamily: Refers to a residential structure that contains five or more units.
Other products: Includes any unreported optional category of loans for which the institution
collects and maintains data for consideration during a CRA examination. Examples of such
activity include consumer loans and other loan data an institution may provide concerning its
lending performance.
Owner-occupied units: Includes units occupied by the owner or co-owner, even if the unit has
not been fully paid for or is mortgaged.
Qualified investment: A qualified investment is defined as any lawful investment, deposit,
membership share, or grant that has as its primary purpose community development.
254
Rated area: A rated area is a state or multistate metropolitan area. For an institution with
domestic branches in only one state, the institution‟s CRA rating would be the state rating. If an
institution maintains domestic branches in more than one state, the institution will receive a
rating for each state in which those branches are located. If an institution maintains domestic
branches in two or more states within a multistate metropolitan area, the institution will receive a
rating for the multistate metropolitan area.
Small loan(s) to business(es): A loan included in 'loans to small businesses' as defined in the
Consolidated Report of Condition and Income (Call Report) and the Thrift Financial Reporting
(TFR) instructions. These loans have original amounts of $1 million or less and typically are
either secured by nonfarm or nonresidential real estate or are classified as commercial and
industrial loans. However, thrift institutions may also exercise the option to report loans secured
by nonfarm residential real estate as "small business loans" if the loans are reported on the TFR
as nonmortgage, commercial loans.
Small loan(s) to farm(s): A loan included in „loans to small farms‟ as defined in the instructions
for preparation of the Consolidated Report of Condition and Income (Call Report). These loans
have original amounts of $500,000 or less and are either secured by farmland, or are classified as
loans to finance agricultural production and other loans to farmers.
Upper-income: Individual income that is more than 120 percent of the area median income, or
a median family income that is more than 120 percent, in the case of a geography.
255

Arvest Bank, Fayetteville, AR, 01-11, 311845 Performance Evaluation

Transcription

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