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Community Reinvestment Act Public File

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COMMUNITY SAVINGS BANK

101 E. Union St.

Edgewood, Iowa 52042

 

 

ASSESSMENT AREA

 

Clayton County:  All Census Tracts

Delaware County: All Census Tracts

Linn County:  All Census Tracts

Dubuque County:  Census Tracts 0102.01, 0102.02, 0104.00, and 0105.00

(March 2023 kjb)

 

OFFICE CLOSINGS AND OPENINGS DURING THE PAST TWO YEARS

 

Garnavillo Branch Relocated from 101 South Main Street Garnavillo Iowa 52049 to 103 West Clayton Street Garnavillo Iowa 52049

(April 2024 kjb)

 

LOAN TO DEPOSIT RATIO

 

March 31, 2023 – 92%

June 30, 2023 – 88%

September 30, 2023 – 84%

December 31, 2023 – 88%

(April 2024 kjb)

 

 

HOME MORTGAGE DISCLOSURE ACT NOTICE

 

The HMDA data about our residential mortgage lending are available online for review. The data shows geographic distribution of loans and applications; ethnicity, race, sex, age, and income of applicants and borrowers; and information about loan approvals and denials. HMDA data for many other financial institutions are also available online. For more information, visit the Consumer Financial Protection Bureau’s Website (www.consumerfinance.gov/hmda).

(March 2023 kjb)

 

COMMUNITY SAVINGS BANK BRANCHES

Cedar Rapids*                                    Monday thru Friday                                                   

3414 Mount Vernon Road SE             9:00 AM – 5:00 PM                                                         

Cedar Rapids, Iowa 52403 

Phone: 319-363-0577

Fax: 319-363-0578

MSA 16300, Census Tract .00016 

                                                                               

Coggon*                              Monday thru Thursday/Lobby           Friday/Lobby                       

203 East Main Street           9:00 AM – 4:00 PM                             9:00 AM – 5:00PM                           

PO Box 139                         

Coggon, Iowa 52218            Monday thru Thursday/Drive-Up      Friday/Drive-Up                  

Phone: 319-435-2551

Fax: 319-435-2555               8:30 AM – 4:00PM                              8:30 AM – 5:00 PM              

MSA 16300, Census Tract 0101.00

 

Dyersville*                           Monday thru Thursday                     Friday                                  

1211 12th Avenue SE           8:30 AM – 4:00 PM                             8:30 AM – 5:00PM              

Suite 103

Dyersville, Iowa 52040

Phone: 563-875-6296

Fax: 563-875-6272

MSA 20220, Census Tract 0105.00

 

Earlville*                             Monday thru Thursday                      Friday                                  Saturday (Drive-Thru Only)

106 Northern Avenue          9:00 AM – 3:00 PM                             9:00 AM – 4:00 PM              8:30 AM – 11:00 AM

Earlville, Iowa 52041

Phone: 563-923-3145

Fax: 563-923-4945

MSA NA (outside of MSA), Census Tract 9501.00

 

Edgewood*                         Monday thru Friday                                                                        Saturday (Drive-Thru Only)

101 East Union Street          9:00 AM – 3:00 PM                                                                          8:30 AM – 11:00 AM

Edgewood, Iowa 52042

Phone: 563-928-6425

Fax: 563-928-6240              

MSA NA (outside of MSA), Census Tract 9502.00

 

Garnavillo*                         Monday thru Thursday                      Friday                                  

103 West Clayton Street         8:30 AM – 4:00 PM                             8:30 AM – 5:00PM               

Garnavillo, Iowa 52049

Phone: 800-828-2318

Fax: 563-964-2485

MSA NA (outside of MSA), Census Tract 0701.00

 

Guttenberg*                        Monday thru Friday                      

502 South Highway 52         8:30 AM – 4:00 PM                        

Guttenberg, Iowa 52052

Phone: 563-252-1048

MSA NA (outside of MSA), Census Tract 0704.00

 

Manchester*                        Monday thru Thursday                      Friday                                  Saturday (Drive-Thru Only)

221 East Main Street           9:00 AM – 4:00 PM                            9:00 AM – 5:00 PM              8:30 AM – 11:00 AM

Manchester, Iowa 52057

Phone: 563-927-4014

Fax: 563-927-2411

MSA NA (outside of MSA), Census Tract 9503.00

 

Marion*                               Monday thru Friday                                                                        Saturday

1295 Blairs Ferry Road       9:00 AM – 5:00 PM                                                                          Not Open

Marion, Iowa 52302

Phone: 319-447-2551

Fax: 319-447-2556

MSA 16300, Census Tract 0003.00

 

Robins*                                Monday thru Friday                                                                        Saturday (Drive-Thru Only)

101 Robins Square Court    9:00 AM – 5:00 PM                                                                          8:30 AM – 11:00 AM

Robins, Iowa 52328

Phone: 319-294-2783

Fax: 319-294-2784

MSA 16300, Census Tract 0002.06

 

*24 Hour ATM Available

 

 

COMMUNITY SAVINGS BANK SERVICE CHARGE MENU

 

Account activity printout (current month) *                                                                           $1.87

Account balancing assistance ($10.00 min.) per hour *                                                         $18.69

Account Closed within 90 days *                                                                                               $14.01

(Charge not applicable to the following checking account types:

Simply Free Checking, Classic 50 Checking, VIP Direct Checking,

Ultimate Interest Checking, Simply Free Business Checking,

Business Interest Checking and Commercial Checking.)

 

Account Research ($10.00 min.)/per hour                                                                              $18.69

Bank Sweep Manager                                                                                                                $28.00

Cashier’s Check – (non CSB Bankclub Member)                                                                      $5.00

Check Cashing non-customer ($5.00 min.)                                                                              3% of amount

Coin Counting non-customers ($5.00 min.)                                                                             5% of amount

Copy of extra statement * (per month)                                                                                   $2.80

Counter Checks                                                                                                                           $1.00 per 5 checks

CSB Debit Card- Annual Fee * (2 card limit)                                                                             $12.00

CSB Debit Card Replacement * (per card)                                                                               $18.69

CSB Debit Card Chargeback Research * (per hour)                                                                 $18.69

CSB Debit Card Hotcard * (includes re-issuance fee)                                                             $18.69

Deposit Book (duplicate pad)                                                                                                     $9.35

Fax (per page)                                                                                                                             $2.00

Foreign/Canadian deposited items *                                                                                       $23.37

Garnishments/Levies                                                                                                                 $50.00

Gift Card                                                                                                                                       $4.95

Inactive Account Fee                                                                                                                  $10.00

Medallion Signature                                                                                                                   $10.00 (CSB Customer)

                                                                                                                                                     $50.00 (non-CSB Customer)

Mortgage amortization schedule                                                                                             $10.00

Night Deposit Key Deposit/Lost                                                                                                $25.00

Night Deposit Bag (Locking)                                                                                                       $25.00

Night Deposit Bag (Zipper)                                                                                                         $5.00

Notary (Non-customer)                                                                                                              $2.00

Outgoing ACH Recurring (per item)                                                                                          $5.00

Overdraft – per item (Consumer limit of 5 per day) ***                                                        $30.00

Paper Statements (per month)                                                                                                $2.80

Personal Money Order (under $5000.00)– (non CSB Bankclub Member)                           $3.00

Photocopy (Black/White)                                                                                                           $.25

Photocopy (Color)                                                                                                                       $.50

Pre-Authorized Automatic Transfer to avoid Overdraft Charge*                                         $4.67

Return Item (NSF) (per presentment)                                                                                      $30.00

Safe Deposit (Replacement key)                                                                                               $15.00

Select Line of Credit- Annual Fee                                                                                              $40.00

Special Statement cut-off*                                                                                                        $4.67

Special Statement handling (waived if E-statement) *                                                          $4.67

Stop Payment*                                                                                                                            $28.04

Travel Card Purchase Card                                                                                                         $9.95

Travel Card Reload Card                                                                                                             $4.95

Wire Transfer Incoming                                                                                                               $10.00

Wire Transfer Domestic outgoing                                                                                             $25.00

Wire Transfer International Outgoing                                                                                      $50.00

Undeliverable Mail Fee                                                                                                              $3.00

Personalized Checks, cost will vary.

*Applicable service charges are subject to Iowa State tax, Local Option tax, and Iowa School Local Option Tax

***Overdrafts can be created by check, in-person withdrawal, ATM withdrawal, or other electronic means.

(March 2024 kjb)

 

COMMUNITY SAVINGS BANK MORTGAGE LOAN PROGRAMS

 

The following mortgage loan programs are offered by Community Savings Bank:

  • Conventional Uninsured (Less than 80% LTV Loans)
  • Conventional Insured (Loans with LTV’s of greater than 80% insured by Private Mortgage Insurance)
  • In-house Mortgages (For borrowers that may not meet secondary market investor guidelines at the current time)
  • IFA FirstHome & IFA FirstHome Plus and Homes for Iowans and Homes for Iowans Plus (Offered through Iowa Finance Authority IFA) Offers low or no down payment fixed rate programs to qualified borrowers.
  • IFA Grants are available in conjunction with IFA FirstHome Plus and IFA Homes for Iowans Plus programs for qualified borrowers. We work with IBMC (Iowa Bankers Mortgage Corporation) for the grant programs.
  • FHLB HomeStart Grant-Funds are available for $7,500 Down Payment Assistance Grants to qualified low-income first-time homeowner households.
  • Mortgage Credit Certificates (MCC’s) Allows the borrower to receive a Federal Tax Credit for a percentage of the interest paid on their home loan. This is funded from year to year by the Iowa Legislature.
  • MHOA Military Home Ownership Assistance Grants administered by the Iowa Finance Authority.
  • USDA Rural Development Guarantee Loans Zero percent down 30-year mortgage with a RD Guarantee instead of PMI
  • Agri-Access Rural Living Loan This program is for rural homes that appraisals may not meet the standard secondary market criteria due to number of acres. We work with IBMC for this program.
  • HOAP Program (forgivable grant for improvements—offered through cities)
  • Community Seconds Program for cities that are offering incentive to build or rehab in certain parts of the city.
  • OSWAP (Onsite Wastewater Assistance Program) Low-interest loans for on-site septic system replacement.

We are able to offer most loan programs offered through the following secondary market investors: Conforming, non-conforming loans and government loans.

Fannie Mae, Universal Lending, AgriAccess, Iowa Finance Authority and Iowa Bankers Mortgage Corporation.

Additionally, we are always looking for new investors, and new programs, that will help a wider variety of borrowers with their mortgage financing needs. This would include low-income borrowers, borrowers with better incomes but no/low down payment, borrowers seeking jumbo financing, and everyone in-between.

(March 2023 kjb)

 

COMMUNITY SAVINGS BANK SERVICES PROVIDED

 

Checking Accounts                                           Savings Accounts                                             Wealth Management                                                                 

Individual Retirement Accounts                    Private Business Account Manager               Money Orders

 

Cashier’s Checks                                              Stop Payment Orders                                      Wire Transfer Service

 

Overdraft Protection                                       Corporate Sweep Manager                            Private Education Loans

 

Gov’t Guaranteed Student Loan Access        Direct Deposit                                                  ACH Origination

 

Safe Deposit Box                                             Night Deposit Box                                            SHAZAM Debit Cards

 

Escrow Service                                                 Notary Service                                                 Tax Collection Service

 

Purchase & Sales of Securities                       Fax Service                                                        Mobile Banking

 

US Savings Bonds through TreasuryDirect.Gov                                                                      Mobile Deposit               

 

Internet Online Banking & Bill Pay                Mobile Website                                               Telephone Money Line Banking                        

Merchant Remote Capture                            Direct Business Loans                                      Website Savings Account Applications

 

Website Consumer Loan Application            Gift Cards                                                          Website Mortgage Loan Applications

 

Credit Cards through Elan                               Direct Consumer Loans                                   Direct Agricultural Loans

 

Website Business Loan Applications             Residential Mortgage Loans                           HELOC  

 

Merchant Card Processing                             

 

**We are an Equal Housing Lender and Member FDIC

(March 2023 kjb)

 


COMMUNITY SAVINGS BANK DEPOSIT PRODUCTS

 

Personal Checking

 

Smart Checking

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

Simple Checking

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

 

 

VIP Direct Checking

*Interest accrues daily based on daily available balance paid monthly.

 

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

 

Ultimate Interest Checking

 

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

Personal Savings

               Regular Savings Account

Star Plus Money Market Account

Christmas Club Account

  • Set aside little by little, year-round for holiday expenses
  • Competitive interest on entire balance
  • No monthly maintenance fee
  • No minimum balance requirements
  • Make deposits at any time, in any amount you feel comfortable with
  • Avoid holiday-induced debt and stress
  • Funds automatically deposited to a Community Savings Bank account in November*
  • Early withdrawal will result in a penalty*
  • Free online banking
  • Free mobile banking with mobile deposit
  • Free e-statements
  • Free telephone banking
  • $1 minimum deposit to open

*All interest earned will be credited annually. You will forfeit all accrued interest if the account is closed prior to it being credited to your account. Minimum deposit to open the account is $1.00.

 

Vacation Club Account

  • Set aside little by little, year-round for vacation expenses
  • Competitive interest on entire balance
  • No monthly maintenance fee
  • No minimum balance requirements
  • Make deposits at any time, in any amount you feel comfortable with
  • Rest easy right from the start; avoid unnecessary debt
  • Funds automatically deposited to a Community Savings Bank account in May*
  • Early withdrawal will result in a penalty*
  • Free online banking
  • Free mobile banking with mobile deposit
  • Free e-statements
  • Free telephone banking
  • $1 minimum deposit to open

*All interest earned will be credited annually. You will forfeit all accrued interest if the account is closed prior to it being credited to your account. Minimum deposit to open the account is $1.00.

 

Youth Savings Account

  • Available to young savers up to 12 years old
  • Competitive interest on entire balance
  • No monthly maintenance fee
  • No minimum balance requirements
  • Establishes the importance and know-how of saving money from an early age
  • 6 free transactions per month by pre-authorized automatic, telephone, checks, drafts, or other similar order; $1 per transaction in excess thereafter
  • Free online banking
  • Free mobile banking with mobile deposit
  • Free e-statements
  • Free telephone banking
  • $50 minimum deposit to open

               Health Savings Account (HSA)

  • Greater personal control over healthcare management and expenses
  • Prepare for qualified medical expenses
  • Earn interest above standard savings on entire balance
  • Receive higher rates on larger deposits
  • An HSA provides triple tax savings:
    • Tax deductions when you contribute to your account
    • Tax-free earnings through investment
    • Tax-free withdrawals for qualified medical, dental, vision expenses, and more*
  • Contributions are tax-free and can be made by you, your employer, or a third party
  • Funds can be withdrawn at any time**
  • No monthly maintenance fee
  • No minimum balance requirements
  • Unused funds remain in account year after year; no "use it or lose it" policy
  • Keep your HSA in your name, regardless of career or life changes
  • Federally insured by FDIC
  • $50 minimum deposit to open

Eligibility

 

Most adults under 65 who are not enrolled in Medicare and are covered under a high-deductible health plan (HDHP) can qualify for an HSA, but it is up to the account holders to determine their own eligibility. Please contact your tax advisor for further eligibility requirements.

 

*Consult a tax advisor.


**You can withdraw funds at any time for any purpose. However, if funds are withdrawn for reasons other than qualified medical expenses, the amount withdrawn will be included as taxable income, and is subject to a 10% penalty.

 

               First-Time Homebuyer Savings Accounts

The State of Iowa has established an Iowa First-Time Homebuyer Savings Account program, which may offer tax advantages on savings for qualified home purchases in Iowa. Accounts may be established by qualifying first-time homebuyers or by others on behalf of qualifying first-time homebuyers. It is important to understand the requirements of the program and you may want to consult your tax advisor.

Learn More About First-Time Homebuyers Savings Account

Home Buyer Savings Includes:

  • No minimum to open.
  • Earn variable interest rates.
  • May claim a deduction for Iowa individual income.

You can learn more about this program by visiting https://tax.iowa.gov/ and searching First-Time Homebuyer Savings Account.

Certificates of Deposit (CDs)

  • Fixed rates, higher than regular savings
  • Receive higher rates by selecting a longer term
  • Provides more guarantee than other risky investments
  • Set aside for future savings goals
  • A wide range of terms available (from 90 days to 5 years)
  • No setup or maintenance fees
  • Early withdrawals subject to penalty*
  • $1,000 minimum deposit to open

*Early withdrawals may result in penalties. Penalties vary depending on the CD.

Individual Retirement Accounts (IRAs)

  • Competitive interest above standard savings rates
  • Traditional and Roth IRA options
  • No setup fees
  • No monthly or annual maintenance fees
  • $5,500 contribution limit per year
  • Additional $1,000 "catch-up" contribution allowed for ages 50+
  • Funds can be used to purchase CDs within IRA
  • No minimum deposit to open

Traditional & Roth IRAs

Traditional IRA

  • No income limits to open
  • No minimum contribution requirement
  • Contributions are tax deductible on state and federal income tax*
  • Earnings are tax deferred until withdrawal (when usually in lower tax bracket)
  • Withdrawals can begin at age 59½
  • Early withdrawals subject to penalty**
  • Mandatory withdrawals at age 70½

Roth IRA

  • Income limits to be eligible to open Roth IRA***
  • Contributions are NOT tax deductible
  • Earnings are 100% tax free at withdrawal*
  • Principal contributions can be withdrawn without penalty*
  • Withdrawals on interest can begin at age 59½
  • Early withdrawals on interest subject to penalty**
  • No mandatory distribution age
  • No age limit on making contributions as long as you have earned income

*Subject to some minimal conditions. Consult a tax advisor. 

**Certain exceptions apply, such as healthcare, purchasing first home, etc.

***Consult a tax advisor.

COVERDELL ESA

College isn’t getting any cheaper. That makes saving for your child’s education so important. Our Coverdell Education Savings Account (ESA) provides a safe, tax-free place to set funds aside — and earn competitive interest. 

  • Set aside funds for your child's education
  • No setup or annual fee
  • Dividends grow tax-free
  • Withdrawals are tax-free and penalty-free when used for qualified education expenses*
  • Designated beneficiary must be under 18 when contributions are made
  • To contribute to an ESA, certain income limits apply**
  • Contributions are not tax deductible
  • $2,000 maximum annual contribution per child
  • The money must be withdrawn by the time he or she turns 30***
  • The ESA may be transferred without penalty to another member of the family
  • $250 minimum deposit to open

*Qualified expenses include tuition and fees, books, supplies, board, etc.

**Consult your tax advisor to determine your contribution limit.

***Those earnings are subject to income tax and a 10% penalty.

Business Checking Accounts

 

Simple Business Checking

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

 

Business Interest Checking

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

 

Commercial Checking

 

***Earnings credit based on balance requirements.

 

*Other fees such as overdraft, return (NSF), paper statements, etc. may apply. See fee schedule for details. Offer good on personal accounts only. Ask us about our great business checking plans including Simple Business Checking. Bank rules and regulations apply. Minimum opening deposit is only $50. Ask us for details.

 

Business Savings Accounts

               Regular Business Savings Account

Business Star Plus Money Market Account

  • Competitive, tiered interest
  • Higher balances earn higher rates
  • Interest accrued daily and paid monthly
  • Enjoy flexibility with enhanced access to funds, including direct check writing:
  • Unlimited in-person withdrawals or by mail
  • 6 free transactions per month by pre-authorized automatic, telephone, checks, drafts, debit cards, or other
  • similar order; $5 per transaction in excess thereafter
  • Avoid the $10.00 monthly service fee by maintaining a $2,500 minimum daily balance
  • Free online banking & bill pay
  • Free mobile banking with mobile deposit
  • Free e-statements
  • Free telephone banking
  • Free Mastercard® debit card
  • $2,500 minimum deposit to open

 

Business Retirement Accounts

               Simplified Employee Pension (SEP IRA)

  • Ideal for businesses of any size or self-employed individuals
  • Gain the respect of your employees
  • Help employees reach their retirement savings goals
  • Employee always has complete ownership of all SEP IRA money
  • Earn competitive interest on entire balance
  • Contributions are tax deductible; your business pays no taxes on earnings
    • Contributions made only by the employer
    • Only self-employed may make contributions on their own behalf
  • Little to no documents to file with government
  • Inexpensive to set up and operate
  • Flexible annual contributions – good plan if cash flow is unpredictable
  • Can contribute up to 25% of each participant's annual compensation (earned income)
    • Or, up to the maximum allowable limit for current plan year, whichever is less
    • Must contribute equally for all employees
  • Employee must first establish a traditional IRA, in which the employer will deposit SEP contributions
  • No minimum deposit to open

Savings Incentive Match Plan for Employees (SIMPLE IRA)

  • Available to any small business – generally with 100 or fewer employees
  • Gain the respect of your employees
    • Employees have the option to make self-contributions
    • Help employees reach their retirement savings goals
    • Employee always has complete ownership of all SIMPLE IRA money
  • Earns a competitive interest rate
  • Employer must not have any other retirement plan
  • Minimal paperwork necessary; no filing requirements
  • Inexpensive to set up and operate
  • Lower contribution limits than some other retirement options
  • Employees share responsibility of growing their retirement
  • Each year, employer is required to contribute:
    • Matching contribution up to 3% of compensation, or
    • 2% non-elective contribution for each eligible employee
  • No minimum deposit to open

COMMUNITY SAVINGS BANK LOAN PRODUCTS

Personal Loans

Student Loans

We work with ISL Education Lending to offer private loans to help you pay for college as well as refinance existing student loans. ISL Education Lending is a nonprofit organization with decades of student loan experience offering lower-priced loans.*

ISL Education Lending offers:

  • Loans for college students.
  • A loan option for parents and family members who wish to borrow on behalf of a college student.
  • Multiple student loan refinance options.

 

In addition, they offer multiple scholarship opportunities and free college planning tools to help students and families avoid overborrowing and plan smart for life during and after college.

Home Mortgage Loans

  • Competitive rates for home purchase, refinance, or construction
  • Several financing programs available
  • Loan advisors with working knowledge of the local real estate market

Home Equity Loans

  • Competitive rates for short-term or ongoing needs
  • The existing equity in your home is used as collateral
  • Term loan and line of credit options available

Parent Refinance Loan

Student Loan Consolidation

  • Competitive rates to consolidate and refinance one or multiple loans
  • One easy payment to manage
  • Private and Federal loans are eligible for consolidation

Auto Loans

  • Competitive rates on new or used vehicles*
  • A wide range of terms customized to your unique situation
  • Pre-approval available for extra bargaining power

Personal Term Loans

  • Competitive rates for a wide variety of personal needs
  • Repayment terms customized to fit your unique needs
  • Local decision-making and processing

Business Loans

Small Business Administration (SBA) Loans

  • Government-assisted financing for qualifying businesses
  • A wide range of lending options available
  • Generally lower down payments and extended terms

Business Term Loans

  • Competitive rates for a wide range of business expenses
  • Repayment terms customized to your business needs
  • Local decision-making and processing

Business Lines of Credit

  • Competitive rates for long-term or seasonal business needs
  • Funds available right as you need them
  • Only pay interest on the part that's used

Accounts Receivables Financing

  • Unlocks working capital and enhances cash flow
  • Provides quick access to cash when you need it
  • More flexibility than traditional financing

Commercial Real Estate Loans

  • Competitive rates to build, buy or refinance commercial properties
  • Available for owner-occupied or investment properties
  • Loan advisors with working knowledge of the local real estate market

 

Agricultural Loans

Equipment Loans

  • Competitive rates for new or used equipment
  • Meet needs without cutting into working capital or savings
  • Avoid lapsed periods in production and outdated equipment

 

Agriculture Real Estate Loans

  • Competitive rates to buy or refinance agriculture properties
  • Repayment terms customized to fit your operation's needs
  • Loan advisors with working knowledge of the local real estate market

Operating Lines of Credit

  • Competitive rates for long-term or seasonal agriculture needs
  • Funds available right as you need them
  • Only pay interest on the part that's used

(March 2023 kjb)

 

COMMUNITY SAVINGS BANK ASSESSMENT AREA MAP 2021

Community Savings Bank Cert 14633

Edgewood, Iowa

ACS - Cedar Rapids Metro AA - Incomes


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Community Savings Bank Cert 14633

Edgewood, Iowa

ACS - Cedar Rapids Metro AA - Income CLOSER

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Community Savings Bank Cert 14633

Edgewood, Iowa

ACS - Dubuque Metro AA - Income

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Community Savings Bank Cert 14633

Edgewood, Iowa

ACS - Non-Metro AA - Income

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PUBLIC DISCLOSURE

 

 

May 6, 2024




COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION

 

Community Savings Bank Certificate Number: 14633


101 East Union Street Edgewood, Iowa 52042





Federal Deposit Insurance Corporation Division of Depositor and Consumer Protection Kansas City Regional Office

1100 Walnut Street, Suite 2100 Kansas City, Missouri 64106





This document is an evaluation of this institution’s record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, nor should it be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution.

TABLE OF CONTENTS

INSTITUTION RATING................................................................................................................ 1

DESCRIPTION OF INSTITUTION............................................................................................... 2

DESCRIPTION OF ASSESSMENT AREAS................................................................................ 3

SCOPE OF EVALUATION........................................................................................................... 3

CONCLUSIONS ON PERFORMANCE CRITERIA.................................................................... 5

DISCRIMINATORY OR OTHER ILLEGAL CREDIT PRACTICES REVIEW....................... 11

NON-METRO ASSESSMENT AREA – Full-Scope Review...................................................... 11

CEDAR RAPIDS METRO ASSESSMENT AREA – Full-Scope Review.................................. 17

DUBUQUE METRO ASSESSMENT AREA – Limited-Scope Review..................................... 23

APPENDICES.............................................................................................................................. 26

INTERMEDIATE SMALL BANK PERFORMANCE CRITERIA........................................ 26

GLOSSARY.............................................................................................................................. 27


INSTITUTION RATING

INSTITUTION’S CRA RATING: This institution is rated Satisfactory.

 

An institution in this group has a satisfactory record of helping to meet the credit needs of its assessment areas, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.


Community Savings Bank’s (CSB) satisfactory Community Reinvestment Act (CRA) performance under both the Lending and Community Development Tests supports the rating. The following points summarize the bank’s Lending Test and Community Development Test performance.


The Lending Test is rated Satisfactory.

  • The loan-to-deposit ratio is reasonable given the institution’s size, financial condition, and credit needs of the assessment areas.
  • A majority of small farm, small business, and home mortgage loans are inside the assessment


  • The geographic distribution of loans reflects reasonable dispersion throughout the assessment areas reviewed.
  • The distribution of borrowers reflects reasonable penetration among farms and businesses of different sizes, as well as individuals of different income levels.
  • The institution did not receive any CRA-related complaints since the previous evaluation; therefore, this factor did not affect the Lending Test rating.


The Community Development Test is rated Satisfactory.

  • The institution demonstrated adequate responsiveness to the community development needs of its assessment areas through community development loans, qualified investments, and community development services. Examiners considered the institution’s capacity, as well as the need and availability of opportunities in the assessment areas.


DESCRIPTION OF INSTITUTION

CSB is a commercial bank headquartered in Edgewood, Iowa. CSB is wholly owned by Community Financial Corporation, Edgewood, Iowa. The institution received a Satisfactory rating at its previous Federal Deposit Insurance Corporation Performance Evaluation dated May 24, 2021, based on Interagency Intermediate Small Institution Examination Procedures. CSB currently operates from ten full-service offices in eastern Iowa. In November 2023, the Garnavillo branch relocated approximately a half mile within the same census tract as the previous location. No branches have been opened or closed and no merger or acquisition activities have occurred during the review period. Further, there are no lending affiliates or subsidiaries for consideration in this evaluation.


CSB offers various loan products, including agricultural, commercial, home mortgage, and consumer loans. CSB’s primary focus is on agricultural and commercial lending. The bank also offers financing alternatives through the following loan programs: Small Business Administration,

U.S. Department of Agriculture Rural Development, Farm Service Agency, Federal Housing Administration, Veterans Administration, Federal Home Loan Bank Homeownership grants, and Iowa Finance Authority. These programs are generally designed to assist small businesses, small farmers, veterans, and low- or moderate-income individuals who may not qualify for loans through conventional financing methods. Secondary market financing options are available for qualifying borrowers. The bank also participated in the Small Business Administration’s Paycheck Protection Program (PPP) during the review period. This program provided financial aid to farms and businesses impacted by the COVID-19 pandemic.


The institution provides a variety of deposit products, including checking, savings, money market, health savings, certificates of deposit, and individual retirement accounts. CSB also offers trust and wealth management services. Alternative banking products or services include debit and credit cards, direct deposit, internet and mobile banking, electronic bill pay, telephone banking, mobile check deposit, electronic statements, and night deposit facilities. Business Management services include credit card processing, Automated Clearing House services, and Remote Deposit. CSB also operates deposit-taking automated teller machines located at all ten bank offices; some with multiple terminals. Interactive teller machines were operational at the Coggon, Cedar Rapids, Guttenberg, and Manchester branch locations, but were converted to automated teller machines in April 2023.


Assets totaled approximately $588.0 million as of March 31, 2024, representing an increase of 17.4 percent since the March 31, 2021, Consolidated Reports of Condition and Income (Call Report).

Total deposits equaled approximately $468.0 million, representing a 15.4 percent increase, and total loans were approximately $427.3 million, representing a 24.0 percent increase during the same timeframe. Portfolio concentrations remained generally consistent over the period; however, residential real estate concentrations increased whereas agriculture and commercial loan concentrations both decreased. Management attributes overall loan and deposit increases to successful strategic growth. The following table illustrates the composition of the loan portfolio as of March 31, 2024.


Loan Portfolio Distribution as of 3/31/2024

Loan Category

$(000s)

%

Construction, Land Development, and Other Land Loans

25,652

6.0

Secured by Farmland

81,695

19.1

Secured by 1-4 Family Residential Properties

75,677

17.7

Secured by Multifamily (5 or more) Residential Properties

9,472

2.2

Secured by Nonfarm Nonresidential Properties

113,157

26.5

Total Real Estate Loans

305,653

71.5

Commercial and Industrial Loans

61,160

14.3

Agricultural Production and Other Loans to Farmers

43,003

10.1

Consumer Loans

11,389

2.7

Obligations of State and Political Subdivisions in the U.S.

3,487

0.8

Other Loans

2,579

0.6

Lease Financing Receivable (net of unearned income)

0

0.0

Less: Unearned Income

(0)

(0.0)

Total Loans

427,271

100.00

Source: Call Report


Examiners did not identify any financial, legal, or other impediments that affect the bank’s ability to meet the credit or community development needs of its assessment areas.


DESCRIPTION OF ASSESSMENT AREAS

The CRA requires each financial institution to define one or more assessment areas within which examiners will evaluate its CRA performance. CSB has defined three contiguous assessment areas within the State of Iowa. The Nonmetropolitan (Non-Metro) Assessment Area is in the nonmetropolitan portion of Iowa. The Cedar Rapids Metro and Dubuque Metro assessment areas are in metropolitan statistical areas (MSAs). Refer to subsequent sections for detailed information on each assessment area.

SCOPE OF EVALUATION

General Information

This evaluation covers the period from the prior evaluation dated May 24, 2021, to the current evaluation date of May 6, 2024. Examiners used the Interagency Intermediate Small Institution Examination Procedures to evaluate the institution’s CRA performance. Related procedures include the Lending and Community Development Tests, which the Appendices describe in detail.

Performance reviews considered the institution’s lending activities in relation to demographics and credit needs of the assessment areas. To evaluate performance, examiners conducted full-scope reviews in the Non-Metro and Cedar Rapids Metro assessment areas, and a limited-scope review in the Dubuque Metro Assessment Area after considering factors such as branching structure, deposit volume, loan volume, market share, and reviews performed at previous CRA evaluations. As shown in the following table, the vast majority of CSB’s loans, deposits, and branches are in the


Non-Metro Assessment Area. Therefore, the bank’s Lending Test and Community Development Test performance in the Non-Metro Assessment Area received the most weight in the overall evaluation. The following table reflects the distribution of loans, deposits, and office locations by assessment area.


Assessment Area Breakdown of Loans, Deposits, and Branches

Assessment Area

Loans

Deposits

Branches

$(000s)

%

$(000s)

%

#

%

Non-Metro

225,233

52.9

329,387

70.4

5

50.0

Cedar Rapids Metro

152,737

35.8

113,278

24.2

4

40.0

Dubuque Metro

48,151

11.3

25,235

5.4

1

10.0

Total

426,121

100.0

467,900

100.0

10

100.0

Source: Bank Data; Federal Deposit Insurance Corporation Summary of Deposits (6/30/2023)


Activities Reviewed

The institution’s major product lines are agricultural, commercial, and residential real estate loans. Examiners based this conclusion on the institution’s business strategy, loan portfolio distribution, and the number and dollar volume of loans originated or renewed during the evaluation period.

Therefore, examiners reviewed small farm, small business, and home mortgage lending to evaluate CSB’s lending performance. Overall, examiners gave greater weight to small farm and small business lending, followed by home mortgage lending, when drawing conclusions given the bank’s lending focus. The table below provides information on the number and dollar volume of loans reviewed.


Loan Products Reviewed


Loan Category

Universe

Universe Inside Assessment Areas

Reviewed*

#

$(000s)

#

$(000s)

#

$(000s)

Small Farm

171

17,277

151

15,377

55

4,298

Small Business

200

29,230

152

19,067

93

7,672

Home Mortgage


2021

518

86,880

388

63,484

388

63,484

2022

373

56,662

283

38,186

283

38,186

2023

221

33,646

171

25,382

171

25,382

Source: Bank Data; HMDA Reported Data; (*) Loans reviewed for the Borrower Profile analysis


For the Assessment Area Concentration review, examiners evaluated lending performance based on all small farm and small business loans originated or renewed in calendar year 2023, as well as Home Mortgage Disclosure Act (HMDA) data collected and reported for 2021, 2022, and 2023.

For the Geographic Distribution review, examiners evaluated lending performance based on all loans located inside the assessment areas containing low- or moderate-income geographies. In addition, 2021 HMDA data was not separately analyzed for Geographic Distribution in the Non- Metro Assessment Area, as there were no low- or moderate-income geographies based on 2015 America Community Survey (ACS) data. For the Borrower Profile analysis, all home mortgage loans within each assessment area were reviewed; however, for small farm and small business


loans, examiners used a sample of loans originated or renewed inside the assessment areas. Small farm lending was not reviewed for Geographic Distribution or Borrower Profile in the Cedar Rapids Metro Assessment Area due to negligible activity caused by low demand, and that it is not a primary business focus in that market. Details are discussed in the applicable assessment area sections.


For small farm and small business conclusions, 2023 D&B data provided a standard of comparison. HMDA aggregate data for 2021 and 2022, 2015 ACS data, and 2020 U.S. Census data provided a standard of comparison for the home mortgage loans reviewed. Examiners primarily focused on CSB’s lending performance in comparison to HMDA aggregate data, when available. Lending performance for 2021 and 2023 was reviewed to ensure that performance was consistent with 2022. In general, examiners did not identify any significant trends between the three years of HMDA data that materially affected conclusions. Therefore, only 2022 HMDA data is presented for the Geographic Distribution and Borrower Profile criteria, as 2022 is the most recent year with available aggregate data. Examiners noted a declining trend in home mortgage lending activity during the review period. Management attributes the falling volume to rising interest rates and related demand. However, the difference in home mortgage lending volume did not result in trends that materially affected conclusions. Any differences in CSB’s home mortgage lending performance between HMDA reporting years are discussed in subsequent sections.


For the Community Development Test, examiners reviewed data presented by management on community development loans, qualified investments, and community development services provided since the prior CRA evaluation.


CONCLUSIONS ON PERFORMANCE CRITERIA

LENDING TEST

CSB demonstrated overall reasonable performance under the Lending Test. The bank’s reasonable performance under each criterion supports this conclusion. The following is a discussion of each performance criterion and how they support the bank’s overall rating.


Loan-to-Deposit Ratio

CSB’s average net loan-to-deposit ratio is reasonable given the institution’s size, financial condition, assessment area credit needs, and in comparison to similarly-situated institutions. The institution’s net loan-to-deposit ratio, calculated from Call Report data, averaged 82.3 percent over the 12 calendar quarters from June 30, 2021, to March 31, 2024. The net loan-to-deposit ratio ranged from a high of 92.3 percent as of December 31, 2023, to a low of 72.2 percent as of June 30, 2022. The ratio generally declined over the first part of the review period as gains in total deposits outpaced net loans. However, the ratio showed significant rebounds beginning in June 2022.

Examiners compared CSB’s average net-loan-to-deposit ratio with those of four similarly-situated institutions to evaluate the institution’s performance. Examiners selected comparable institutions based on similarities in lending focus, asset size, or markets served. As shown in the following table, CSB’s ratio is similar to comparable institutions.


Loan-to-Deposit Ratio Comparison

Bank

Total Assets as of 3/31/24

($000s)

Average Net Loan-to-Deposit Ratio

(%)

Community Savings Bank, Edgewood, Iowa

587,961

82.3

BankIowa, Cedar Rapids, Iowa

845,894

83.6

FreedomBank, Elkader, Iowa

450,917

78.0

Farmers & Merchants Savings Bank, Manchester, Iowa

612,413

77.0

Citizens State Bank, Monticello, Iowa

511,355

51.7

Source: Call Reports 6/30/2021 – 3/31/2024


The institution also originates and subsequently sells mortgage loans through secondary market relationships; these loans are not included in the institution’s ratio. CSB reported originating and selling 365 loans totaling approximately $58.7 million on the secondary market from the prior evaluation date through March 31, 2024. While the sale of secondary market loans does not influence the average net loan-to-deposit ratio, this activity provides liquidity to originate additional home mortgage loans. Secondary market lending is responsive to the assessment area’s credit needs by providing long-term home mortgage financing.


Assessment Area Concentration

As shown in the following table, the institution originated a majority of small farm, small business, and home mortgage loans inside its assessment areas.


Lending Inside and Outside of the Assessment Areas


Loan Category

Number of Loans


Total #

Dollar Amount of Loans $(000s)


Total

$(000s)

Inside

Outside

Inside

Outside

#

%

#

%

$

%

$

%

Small Farm

151

88.3

20

11.7

171

15,377

89.3

1,850

10.7

17,227

Small Business

152

76.0

48

24.0

200

19,067

65.2

10,163

34.8

29,230

Home Mortgage


2021

388

74.9

130

25.1

518

63,484

73.1

23,396

26.9

86,880

2022

283

75.9

90

24.1

373

38,186

67.4

18,477

32.6

56,663

2023

171

77.4

50

22.6

221

25,382

75.4

8,264

24.6

33,646

Home Mortgage Total

842

75.7

270

24.3

1,112

127,052

71.7

50,137

28.3

177,189

Source: Bank Data

Due to rounding, totals may not equal 100.0%


Geographic Distribution

The geographic distribution of loans reflects reasonable dispersion throughout the reviewed assessment areas. The review of this criterion focused on the institution’s record of lending in low- and moderate-income census tracts within the Non-Metro and Cedar Rapids Metro assessment areas. The bank’s reasonable lending performance in the Non-Metro Assessment Area, which was provided the most weight, supports this conclusion. Although poor dispersion was noted in the


Cedar Rapids Metro Assessment Area due to its small business performance, it did not influence the overall conclusion. Examiners focused primarily on the percentage, by number of loans, in low- and moderate-income census tracts located in each of the assessment areas. The Dubuque Metro Assessment Area has no low- or moderate-income census tracts; therefore, this criterion was not evaluated for this assessment area. Refer to comments under each separately analyzed assessment area for a more specific analysis.


Borrower Profile

The distribution of borrowers reflects reasonable penetration among farms and businesses of different sizes, and individuals of different income levels. The bank’s reasonable lending performance in each assessment area supports this conclusion. Examiners focused on the percentage, by number of loans, to businesses and farms generating gross annual revenues of $1 million or less, and on the percentage, by number of loans, to low- and moderate-income borrowers. Refer to comments under each separately analyzed assessment area for a more specific analysis.


Response to Complaints

The institution has not received any CRA-related complaints since the previous evaluation; therefore, this criterion did not affect the Lending Test rating.


COMMUNITY DEVELOPMENT TEST

CSB demonstrated adequate responsiveness to the community development needs of its assessment areas through community development loans, qualified investments, and community development services. Examiners considered the institution’s capacity and the need and availability of such opportunities to evaluate the bank’s performance under this test. Because the bank was responsive to the community development needs of its assessment areas, community development activities benefitting the broader statewide or regional area were included in the analysis.

Information from performance evaluations of three intermediate small banks conducted during the evaluation period was used for comparative purposes to assess CSB’s overall performance under the Community Development Test. The institutions were chosen due to similarities in asset size or types of areas served. CSB’s overall community development performance compared reasonably to these institutions when considering available community development opportunities in the assessment areas.


Community Development Loans

CSB originated 75 community development loans totaling approximately $7.8 million during the evaluation period. As the bank was responsive to assessment area community development needs, the overall total also includes $881,000 in community development loans benefitting the broader statewide area that includes the bank’s assessment areas. CSB extended loans to entities to promote economic development by supporting permanent job creation, retention, and/or improvement for low- and moderate-income persons, and to aid revitalization or stabilization efforts.

CSB’s total community development loans represent 1.3 percent of total assets and 1.8 percent of net loans, as of March 31, 2024. The comparable institutions had community development loans to total assets ratios ranging from 0.9 percent to 2.4 percent, and community development loans to net


loans ratios ranging from 1.8 percent to 4.8 percent. CSB’s ratios compare reasonably to these institutions. As all three comparable institutions’ community development lending activity also included a significant number of PPP loans, examiners calculated comparable bank ratios exclusive of this activity. In comparison to the prior evaluation, CSB’s community development loans increased substantially by both number and dollar volume from 53 loans totaling $1.3 million, when excluding the prior evaluation’s PPP activity. The following tables reflect the number and dollar volume of community development lending in each category by assessment area and activity year.


Community Development Lending by Assessment Area


Assessment Area

Affordable Housing

Community Services

Economic Development

Revitalize or Stabilize

Totals

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

Non-Metro

0

0

0

0

48

3,484

3

354

51

3,838

Cedar Rapids Metro

0

0

0

0

13

2,862

2

180

15

3,042

Dubuque Metro

0

0

0

0

0

0

0

0

0

0

Statewide

0

0

0

0

3

809

6

72

9

881

Total

0

0

0

0

64

7,155

11

606

75

7,761

Source: Bank Records


Community Development Lending


Activity Year

Affordable Housing

Community Services

Economic Development

Revitalize or Stabilize

Totals

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

2021 (Partial Year)

0

0

0

0

15

1,109

1

66

16

1,175

2022

0

0

0

0

31

1,891

5

344

36

2,235

2023

0

0

0

0

16

4,120

4

36

20

4,156

2024 (Year-to-Date)

0

0

0

0

2

35

1

160

3

195

Total

0

0

0

0

64

7,155

11

606

75

7,761

Source: Bank Records


Examples of community development lending where the bank has been most responsive to community development needs are discussed in the individual assessment area sections of this evaluation, as applicable.


Qualified Investments

During the evaluation period, CSB made 143 qualified investments totaling approximately $20.8 million, which includes 101 donations of approximately $236,000. As the bank was responsive to assessment area community development needs, these totals also include 31 investments and donations totaling approximately $17.2 million benefitting the broader statewide and regional area that includes the bank’s assessment areas.

CSB’s qualified investments represented 3.5 percent of total assets and 16.5 percent of total securities, as of March 31, 2024. The comparable institutions’ qualified investments ratios ranged from 0.4 percent to 2.7 percent of total assets, and 1.9 percent to 6.5 percent of total securities.

CSB’s performance is favorable to these institutions. CSB’s ratios have increased since the prior


evaluation when qualified investments represented 1.7 percent of total assets and 8.8 percent of total securities. Examiners recognize that donations drastically increased compared to the prior evaluation’s total of $87,000, which can be more impactful on a community. The following tables reflect the number and dollar volume of qualified investments by assessment area, purpose, and activity year.


Qualified Investments by Assessment Area


Assessment Area

Affordable Housing

Community Services

Economic Development

Revitalize or Stabilize

Totals

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

Non-Metro

0

0

9

7

20

1,032

57

2,343

86

3,382

Cedar Rapids Metro

2

6

7

5

15

27

2

220

26

258

Dubuque Metro

0

0

0

0

0

0

0

0

0

0

Statewide Activities

0

0

1

<1

0

0

4

2,420

5

2,420

Regional Activities

2

965

5

6,465

14

5,500

5

1,805

26

14,735

Total

4

971

22

6,477

49

6,559

68

6,788

143

20,795

Source: Bank Data


Qualified Investments


Activity Year

Affordable Housing

Community Services

Economic Development

Revitalize or Stabilize

Totals

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

#

$(000s)

Prior Period

0

0

4

5,465

0

0

7

2,520

11

7,985

2021 (Partial Year)

0

0

1

1,000

1

1,200

5

2,245

7

4,445

2022

2

965

0

0

0

0

5

1,870

7

2,835

2023

0

0

0

0

0

0

0

0

0

0

2024 (Year-to-Date)

0

0

0

0

17

5,294

0

0

17

5,294

Subtotal

2

965

5

6,465

18

6,494

17

6,635

42

20,559

Qualified Grants & Donations

2

6

17

12

31

65

51

153

101

236

Total

4

971

22

6,477

49

6,559

68

6,788

143

20,795

Source: Bank Data

Examples of qualified investments where the bank has been most responsive to community development needs are discussed in the individual assessment area sections of this evaluation, as applicable. Such examples are limited to donations, as equity investments that received consideration were not unique and are similar to those generally seen at other institutions.


Community Development Services

The bank received consideration for a total of 73 community development services that primarily consisted of providing support to economic development- and revitalization/stabilization-related organizations. CSB personnel provided technical or financial expertise to these organizations in many ways, all related to their employment with the institution. Employees dedicated their time and resources to 29 different organizations over the evaluation period. Most notably, in the majority of these entities, bank employees served in a board member or officer capacity.


Comparable institutions provided between 22 and 77 services; CSB compares reasonably to these institutions. The following tables illustrate the bank’s community development services in each category by assessment area and activity year.


Community Development Services by Assessment Area


Assessment Area

Affordable Housing

Community Services

Economic Development

Revitalize or Stabilize

Totals

#

#

#

#

#

Non-Metro

5

2

22

20

49

Cedar Rapids Metro

1

5

8

0

14

Dubuque Metro

0

0

10

0

10

Total

6

7

40

20

73

Source: Bank Data


Community Development Services


Activity Year

Affordable Housing

Community Services

Economic Development

Revitalize or Stabilize

Totals

#

#

#

#

#

2021 (Partial Year)

1

1

7

6

15

2022

2

2

11

4

19

2023

2

2

11

5

20

2024 (Year-to-Date)

1

2

11

5

19

Total

6

7

40

20

73

Source: Bank Data


CSB offers retail services that increase access to financial services in the assessment areas, which include the alternative services described under this document’s Description of Institution section. These services are generally free of charge to bank customers, which benefits low- and moderate- income individuals. CSB operates two branch offices and automated teller machines in underserved middle-income geographies. Consumer and commercial checking accounts are offered with no minimum balance or service fees.


As mentioned previously, the bank participates in various lending programs that aid small businesses, small farms, and potential homeowners. The bank originated three PPP loans totaling nearly $57,000, since the last evaluation. CSB also continued to offer loan accommodations and overdraft fee waiving measures implemented to accommodate customers affected by the COVID-19 pandemic.


Retail banking services and loan programs are consistent among CSB’s assessment areas. The institution also invests in, and is involved with, other community activities that do not specifically meet the definition of community development; however, bank personnel are commended for their involvement in these other community events. Qualitative examples of community development services where the bank was responsive are mentioned in the individual assessment area sections of this evaluation, as applicable.


DISCRIMINATORY OR OTHER ILLEGAL CREDIT PRACTICES REVIEW

The bank’s compliance with the laws relating to discrimination and other illegal credit practices was reviewed, including the Fair Housing Act and the Equal Credit Opportunity Act. Examiners did not identify any evidence of discriminatory or other illegal credit practices inconsistent with helping meet community credit needs.


NON-METRO ASSESSMENT AREA – Full-Scope Review

DESCRIPTION OF INSTITUTION’S OPERATIONS IN THE NON-METRO ASSESSMENT AREA

The Non-Metro Assessment Area consists of Clayton and Delaware counties in their entirety, which are non-metropolitan in nature. CSB operates from five offices in the assessment area.


Economic and Demographic Data

According to 2020 U.S. Census data, the assessment area consists of ten census tracts, including one moderate- and nine middle-income tracts. Clayton County census tract 701 changed from middle- to moderate-income and Delaware County census tract 9502 changed from upper- to middle-income since the previous evaluation. The moderate-income census tract is along the Mississippi River in the northeast corner of the assessment area. During the review period, Clayton County census tracts 702-705 were designated annually as underserved middle-income geographies; Clayton County census tract 701 was designated as underserved in 2021. The following table illustrates select demographic characteristics of the Non-Metro Assessment Area.


Demographic Information of the Assessment Area

Demographic Characteristics

#

Low

% of #

Moderate

% of #

Middle

% of #

Upper

% of #

NA*

% of #

Geographies (Census Tracts)

10

0.0

10.0

90.0

0.0

0.0

Population by Geography

34,531

0.0

8.3

91.7

0.0

0.0

Housing Units by Geography

17,241

0.0

9.8

90.2

0.0

0.0

Owner-Occupied Units by Geography

11,285

0.0

9.3

90.7

0.0

0.0

Occupied Rental Units by Geography

3,193

0.0

12.3

87.7

0.0

0.0

Vacant Units by Geography

2,763

0.0

9.5

90.5

0.0

0.0

Businesses by Geography

4,664

0.0

8.3

91.7

0.0

0.0

Farms by Geography

897

0.0

9.7

90.3

0.0

0.0

Family Distribution by Income Level

9,470

15.7

18.3

24.9

41.1

0.0

Household Distribution by Income Level

14,478

20.1

18.2

18.0

43.7

0.0

Median Family Income - Non-metropolitan Iowa

$71,763

Median Housing Value

$137,942

Median Gross Rent

$637

Families Below Poverty Level

5.2%

Source: 2020 U.S. Census and 2023 D&B Data. (*) The NA category consists of geographies that have not been assigned an income classification. Due to rounding, totals may not equal 100.0%.


According to 2023 D&B data, service industries represent the largest portion of businesses and farms at 27.0 percent; followed by non-classifiable establishments at 19.5 percent; agriculture, forestry, and fishing at 16.1 percent; and retail trade at 8.8 percent. In addition, 68.5 percent of assessment area farms and businesses have four or fewer employees, and 93.1 percent operate from a single location.


The FFIEC-estimated median family income levels are used to analyze home mortgage loans under the Borrower Profile criterion and to analyze certain community development activities. The median family income levels for the non-metropolitan areas of Iowa are presented in the following table by year.


Median Family Income Ranges

2021 ($70,500)

<$35,250

$35,250 to <$56,400

$56,400 to <$84,600

≥$84,600

2022 ($78,900)

<$39,450

$39,450 to <$63,120

$63,120 to <$94,680

≥$94,680

2023 ($86,300)

<$43,150

$43,150 to <$69,040

$69,040 to <$103,560

≥$103,560

Source: FFIEC

Competition

CSB’s assessment area is considered moderately competitive in the market for financial services. The Federal Deposit Insurance Corporation Deposit Market Share Report as of June 2023 reflects that 12 insured institutions operate from 24 offices within the assessment area. These institutions mostly consist of smaller community banks operating branch offices in the area. Of these institutions, CSB ranked 2nd with 11.7 percent of the deposit market share. The top ranking bank held 45.7 percent of the deposit market share.

Additionally, although the bank is not required to collect or report its small business or small farm loan data, and analyses under the Lending Test do not include direct comparisons to aggregate lending data, this aggregate lending data reflects the level of demand for these loan types and may be referenced throughout this evaluation for this purpose. CRA aggregate data for 2022 shows 17 lenders reported 655 small farm loan originations and 41 lenders reported 607 small business loan originations in the assessment area. To further illustrate the level of competition and demand for loans, 2022 HMDA aggregate data shows 89 institutions reported 904 home mortgage loan originations/purchases within the assessment area. CSB ranked 1st with 17.2 percent of the market share by number of loans.


Community Contact

As part of the evaluation process, examiners contact third parties active in the assessment area to assist in understanding economic conditions and identifying credit needs. This information helps to determine whether local financial institutions are responsive to community credit needs and provides context regarding available lending opportunities.

Examiners referenced an interview with a representative from an economic development organization within the assessment area. The contact noted the economy is centered around agriculture. While farmers have been enjoying wider margins and higher commodity prices in recent years, prices have started to contract and inputs have stayed the same or become more expensive. Smaller farms are disappearing as larger farms consolidate with them, but the pace has


slowed in recent years. There is low unemployment due to increasing manufacturing activity in the area. Larger firms have either expanded or moved to the area, and smaller firms (under 50 employees) are also doing well. The availability of housing is tight, especially affordable housing; however, the housing market showed signs of easing during the previous year. The housing shortage has also kept housing prices and rentals higher than average. Some housing starts (individual and multi-family) have been made recently, in light of the anticipated job growth in the manufacturing sector. Affordable housing is available, but is generally not near manufacturing sites; therefore, transportation for workers can be an issue.


Credit and Community Development Needs and Opportunities

Considering information from the community contact, bank management, and demographic and economic data, small farm, small business, and home mortgage loans (especially affordable housing) are the primary credit needs of the assessment area. Call Reports filed by area financial institutions also support this assertion. Analyses performed show that community development opportunities exist in the area, though on a limited basis due to lower population and need.


CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NON-METRO ASSESSMENT AREA

LENDING TEST

CSB demonstrated reasonable performance under the Lending Test in the Non-Metro Assessment Area, as supported by reasonable Geographic Distribution and Borrower Profile performance.


Geographic Distribution

The institution’s geographic distribution of loans reflects reasonable dispersion throughout the assessment area. The bank’s reasonable performance in all three lending products supports this conclusion.


Small Farm Loans

The geographic distribution of small farm lending reflects reasonable dispersion given the performance context. As shown in the following table, the institution’s lending in the assessment area’s one moderate-income census tract is lower than the demographic data; however, D&B’s reporting reflects that a small percentage of farms are located within this census tract (9.7 percent). Review of the bank’s agricultural lending since the prior evaluation noted limited originations in the northern section of Clayton County; however, this appears consistent with prior dispersions.

Management stated and examiners confirmed that the legacy Edgewood branch, which is located on the south border of Clayton County, handles a majority of CSB’s agricultural lending and houses a more experienced lending team. The sole moderate-income census tract resides in the northeast section of Clayton County, approximately 30 miles from the Edgewood office, and was previously designated by 2015 ACS as a middle-income geography. Management also explained that competition is a significant factor. Examiners confirmed this statement noting that 2022 CRA Aggregate shows 17 lenders reported 655 small farm loans with 13.3 percent of total loans in the moderate-income census tract. Two of these lenders, which are larger community-based banks,


dominate the market share and have a greater presence in this specific area. Further, this rural assessment area is comprised of several middle-income census tracts and as expected, CSB’s lending dispersion corresponds to the loan product type and related demand. Management stated goals are in place to expand the bank’s footprint into the northern section of Clayton County, now that a more experienced agriculture lender is located in the Garnavillo branch.


Geographic Distribution of Small Farm Loans

Tract Income Level

% of Farms

#

%

$(000s)

%

Moderate

9.7

3

2.5

425

3.3

Middle

90.3

118

97.5

12,309

96.7

Totals

100.0

121

100.0

12,734

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%

Small Business Loans

The geographic distribution of small business lending reflects reasonable dispersion given the performance context. As shown in the following table, the institution’s lending in the assessment area’s one moderate-income census tract is higher than the demographic data; however, examiner review of the data noted all loans were extended to the same borrower. D&B’s reporting reflects a small percentage of businesses are located within this census tract (8.3 percent). Examiner and management comments made in the small farm analysis above with respect to loan dispersion, examiner expanded reviews of loan since the prior evaluation, branch proximity and production, competition, and planned market penetration are also true for small business lending. CRA Aggregate for 2022 shows 41 lenders reported 607 small business loans with 8.7 percent of total loans in the moderate-income census tract, with the same two lenders ruling the market, as noted above.


Geographic Distribution of Small Business Loans

Tract Income Level

% of Businesses

#

%

$(000s)

%

Moderate

8.3

13

15.3

2,077

18.4

Middle

91.7

72

84.7

9,187

81.6

Totals

100.0

85

100.0

11,264

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%


Home Mortgage Loans

The geographic distribution of home mortgage loans reflects reasonable penetration throughout the assessment area when compared to aggregate data. As shown in the following table, the bank’s record of originating home mortgage loans in the moderate-income census tract is similar to aggregate data.


Geographic Distribution of Home Mortgage Loans


Tract Income Level

% of Owner- Occupied Housing Units

Aggregate Performance

% of #


#


%


$(000s)


%

Moderate

9.3

6.1

9

5.8

808

4.0

Middle

90.7

93.9

146

94.2

19,249

96.0

Totals

100.0

100.0

155

100.0

20,057

100.0

Source: 2020 U.S. Census; Bank Data; 2022 HMDA Aggregate Data. Due to rounding, totals may not equal 100.0%


Borrower Profile

The distribution of borrowers reflects reasonable penetration among farms and businesses of different sizes and individuals of different income levels. The bank’s reasonable performance in all three lending products supports this conclusion.


Small Farm Loans

The distribution of small farm loans among agricultural operations of different sizes reflects reasonable penetration. As shown in the following table, CSB’s lending to farms with gross annual revenues of $1 million or less is slightly lower, yet still comparable to the number of farms in this revenue category.


Distribution of Small Farm Loans by Gross Annual Revenue Category

Gross Revenue Level

% of Farms

#

%

$(000s)

%

<=$1,000,000

98.7

31

88.6

2,008

75.0

>$1,000,000

0.6

4

11.4

668

25.0

Revenue Not Available

0.8

0

0.0

0

0.0

Total

100.0

35

100.0

2,676

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%

Small Business Loans

The distribution of small business loans among commercial operations of different sizes reflects reasonable penetration. CSB’s lending to businesses with gross annual revenues of $1 million or less is slightly lower, yet still comparable to the number of businesses in this revenue category. See the following table.


Distribution of Small Business Loans by Gross Annual Revenue Category

Gross Revenue Level

% of Businesses

#

%

$(000s)

%

<=$1,000,000

89.1

34

85.0

2,035

61.1

>$1,000,000

2.7

6

15.0

1,297

38.9

Revenue Not Available

8.2

0

0.0

0

0.0

Total

100.0

40

100.0

3,332

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%


Home Mortgage Loans

CSB’s performance in extending home mortgage loans to borrowers of differing income levels is reasonable. As shown in the table below, the institution’s performance in lending to low-income borrowers in 2022 mirrors aggregate lending data. Lending to moderate-income borrowers was modestly below that of aggregate lending data. Examiners noted similar performance at the prior evaluation.


Distribution of Home Mortgage Loans by Borrower Income Level


Borrower Income Level


% of Families

Aggregate Performance

% of #


#


%


$(000s)


%

Low

15.7

9.0

14

9.0

1,066

5.3

Moderate

18.3

24.1

32

20.6

2,158

10.8

Middle

24.9

23.5

35

22.6

4,135

20.6

Upper

41.1

31.4

60

38.7

10,970

54.7

Not Available

0.0

12.1

14

9.0

1,728

8.6

Totals

100.0

100.0

155

100.0

20,057

100.0

Source: 2020 U.S. Census; Bank Data; 2022 HMDA Aggregate Data. Due to rounding, totals may not equal 100.0%


COMMUNITY DEVELOPMENT TEST

CSB’s community development performance demonstrates adequate responsiveness to community development needs in the Non-Metro Assessment Area, considering the institution’s capacity, as well as the need and availability of such community development opportunities.


Community Development Loans

The bank originated 51 community development loans totaling nearly $3.8 million in this assessment area. One notable example includes a loan to purchase the assets of a business located in the moderate-income census tract in Clayton County. The loan allowed the business to remain open and assisted in revitalizing and stabilizing a moderate-income area by retaining an existing business.


Qualified Investments

The bank made 86 qualified investments totaling nearly $3.4 million that received consideration during this evaluation. Notable examples include multiple sizable donations to fund the expansion of a childcare facility and the updating of school buildings. These donations enabled the improvement of essential infrastructure in an underserved area.


Community Development Services

The bank received consideration for 49 community development services, which mostly consisted of bank employees providing financial expertise to organizations promoting economic development and revitalization or stabilization efforts within the assessment area. Several of the services provided were targeted toward revitalization and/or stabilization efforts in middle-income geographies designated as underserved. Several qualifying services targeted medical, emergency services, and other essential infrastructure needs.


CEDAR RAPIDS METRO ASSESSMENT AREA – Full-Scope Review

DESCRIPTION OF INSTITUTION’S OPERATIONS IN THE CEDAR RAPIDS METRO ASSESSMENT AREA

The Cedar Rapids Metro Assessment Area consists of Linn County in its entirety, which is part of the Cedar Rapids, Iowa MSA. While the boundaries of the Cedar Rapids Metro Assessment Area have not changed since the prior evaluation, the number of census tracts comprising the assessment area increased from 45 to 54 due to population growth noted by the 2020 U.S. Census. The Cedar Rapids Metro Assessment Area continues to have one census tract designated as “not applicable”; however, it is not the same census tract as previously categorized. Currently, Linn County census tract 2.13 is classified as “not applicable”. A comparison of 2015 ACS data and 2020 U.S. Census data reflects the transition of tracts between income categories. In aggregate, allocation of this area’s 54 geographies by income level revealed a decrease of one low-income census tract and an increase of four moderate-, three middle-, and three upper-income census tracts, and a decrease of ten middle-income census tracts. Management indicated the primary business focus in this assessment area is commercial lending.


Economic and Demographic Data

CSB’s Cedar Rapids Metro Assessment Area is comprised of one low-, 15 moderate-, 28 middle-, nine upper-income geographies, as well as one in which an income designation is not applicable (commercial/retail space on the north side of Cedar Rapids). CSB operates from four offices in this assessment area. The following table illustrates select demographic characteristics of the assessment area.


Demographic Information of the Assessment Area

Demographic Characteristics

#

Low

% of #

Moderate

% of #

Middle

% of #

Upper

% of #

NA*

% of #

Geographies (Census Tracts)

54

1.9

27.8

51.9

16.7

1.9

Population by Geography

230,299

1.2

21.3

54.5

21.9

1.2

Housing Units by Geography

98,022

0.8

23.6

55.0

19.1

1.5

Owner-Occupied Units by Geography

67,843

0.1

19.2

55.8

24.6

0.3

Occupied Rental Units by Geography

23,461

2.1

35.2

52.8

5.2

4.7

Vacant Units by Geography

6,718

2.8

28.1

55.4

11.8

1.9

Businesses by Geography

29,158

5.7

21.7

47.8

21.9

2.8

Farms by Geography

1,225

2.8

10.8

58.2

27.3

0.9

Family Distribution by Income Level

57,087

18.6

19.0

22.7

39.8

0.0

Household Distribution by Income Level

91,304

21.4

17.7

18.9

42.0

0.0

Median Family Income - Cedar Rapids, Iowa MSA

$85,854

Median Housing Value

$163,819

Median Gross Rent

$760

Families Below Poverty Level

6.3%

Source: 2020 U.S. Census and 2023 D&B Data. (*) The NA category consists of geographies that have not been assigned an income classification. Due to rounding, totals may not equal 100.0%


According to 2023 D&B data, service industries represent the largest portion of businesses and farms at 34.0 percent; followed by non-classifiable establishments at 22.7 percent; finance, insurance, and real estate at 12.8 percent; and retail trade at 9.7 percent. In addition, 63.6 percent of assessment area farms and businesses have four or fewer employees, and 92.5 percent operate from a single location.


The FFIEC-estimated median family income levels are used to analyze home mortgage loans under the Borrower Profile criterion and to analyze certain community development activities. The median family income levels for the Cedar Rapids, Iowa MSA are presented in the following table by year.


Median Family Income Ranges

Median Family Incomes

Low

<50%

Moderate 50% to <80%

Middle 80% to <120%

Upper

≥120%

2021 ($87,300)

<$43,650

$43,650 to <$69,840

$69,840 to <$104,760

≥$104,760

2022 ($89,200)

<$44,600

$44,600 to <$71,360

$71,360 to <$107,040

≥$107,040

2023 ($96,300)

<$48,150

$48,150 to <$77,040

$77,040 to <$115,560

≥$115,560

Source: FFIEC

Competition

FSB’s assessment area is considered highly competitive in the market for financial services. The Federal Deposit Insurance Corporation Deposit Market Share Report as of June 2023 reflects that 27 insured institutions operate from 73 offices within the assessment area. These institutions range


from small community banks to larger financial institutions operating branch offices in the area. Of these institutions, CSB ranked 13th with 1.8 percent of the deposit market share. The top five banks held 73.9 percent of the deposit market share. In addition, 2023 data obtained from the National Credit Union Administration’s website shows 10 credit unions with at least one location within the assessment area and reports nearly $20.0 billion dollars in deposits. Further, CRA aggregate data for 2022 shows 80 lenders reported 3,774 small business loan originations in the assessment area, which demonstrates competition and demand for small business loans.


Community Contact

Examiners referenced one previous contact from an economic development organization serving the assessment area. The contact stated that the economy is generally stable. Commercial development in the assessment area is growing slowly, but steadily. One area of concern is the declining occupancy rate for commercial office space, fueled by the remote work trend. Main street businesses in rural areas are struggling due to the preference of shoppers to go to larger retail areas. Low unemployment has had an effect on both agricultural and business employers, forcing wages up and making hiring harder for smaller entities. The residential real estate market has become much stronger over the past few years, as homeowners are spending equity funds to renovate and repair existing homes. With new home inventory being low, high demand for housing, and high construction input costs, the price of new housing has risen substantially. Finally, the refinance market has cooled considerably due to rising interest rates.


Credit and Community Development Needs and Opportunities

Considering information from the community contact, bank management, and demographic and economic data, examiners determined that commercial and home mortgage loans are primary credit needs of the assessment area. Call Reports filed by area financial institutions also support this assertion. The community contact stated that the main credit needs in the area are for general agriculture, business credit related to minority and women-owned businesses, as well as rural main street small business credit, and affordable housing credit, especially in rural areas. There are numerous opportunities for community development lending, investments, and services in the area. Finally, the community contact stated that the environment for involvement by financial institutions is very competitive.


CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CEDAR RAPIDS METRO ASSESSMENT AREA

LENDING TEST

CSB demonstrated overall reasonable performance under the Lending Test in the Cedar Rapids Metro Assessment Area, as supported by the combination of poor Geographic Distribution and excellent Borrower Profile performances.


Geographic Distribution

The institution’s geographic distribution of loans reflects poor dispersion throughout the assessment area. The bank’s poor performance in small business lending, which is given the most weight, supports this conclusion.


Small Business Loans

The geographic distribution of small business lending reflects poor dispersion. As shown in the following table, CSB originated no small business loans in the sole low-income census tract in 2023. No additional loans were identified through a review of the institution’s lending activity since the previous evaluation. D&B reports limited opportunities within this tract as well. With respect to lending in moderate-income census tracts, the bank’s percentage of small business loans is significantly below benchmark data. An expanded review revealed similar penetration throughout the evaluation period. Examiners noted a declination in performance when compared to the prior evaluation. Management recognized competition as a significant factor and noted they continue to expand their footprint into the Cedar Rapids-area market. Examiners concurred with this assessment, identifying 14 lenders from 12 locations just within the moderate-income census tracts. The community contact also identified the area as a very competitive market.


Geographic Distribution of Small Business Loans

Tract Income Level

% of Businesses

#

%

$(000s)

%

Low

5.7

0

0.0

0

0.0

Moderate

21.7

2

5.1

267

4.4

Middle

47.8

21

53.8

2,096

34.6

Upper

21.9

15

38.5

3,349

55.3

Not Available

2.8

1

2.6

340

5.6

Totals

100.0

39

100.0

6,052

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%


Home Mortgage Loans

The geographic distribution of home mortgage loans reflects reasonable penetration throughout the assessment area when compared to aggregate data. As shown in the following table, the bank’s record of originating home mortgage loans in both low- and moderate-income geographies is favorable to aggregate data. However, examiners noted multiple loans being originated to a limited number of different borrowers in both low- and moderate-income geographies, which can inflate results. Both demographics and aggregate data reveal limited opportunity within the sole low-income census tract. Examiners noted similar performance in both low- and moderate-income census tracts when compared to the last evaluation.


Geographic Distribution of Home Mortgage Loans


Tract Income Level

% of Owner- Occupied Housing Units

Aggregate Performance

% of #


#


%


$(000s)


%

Low

0.1

0.3

2

1.9

121

0.8

Moderate

19.2

21.2

27

26.0

2,542

17.1

Middle

55.8

53.1

51

49.0

7,409

49.9

Upper

24.6

25.0

20

19.2

4,436

29.9

Not Available

0.3

0.5

4

3.8

351

2.4

Totals

100.0

100.0

104

100.0

14,859

100.0

Source: 2020 U.S. Census; Bank Data; 2022 HMDA Aggregate Data. Due to rounding, totals may not equal 100.0%


Borrower Profile

The distribution of borrowers reflects excellent penetration among businesses of different sizes and individuals of different income levels. The bank’s excellent performance in small business lending, which is given the most weight, supports this conclusion.


Small Business Loans

The distribution of small business loans among businesses of different sizes reflects excellent penetration. CSB’s small business lending is higher than demographic data. Examiner review of bank data also noted loans being extended to a variety of small business entities. See the following table.


Distribution of Small Business Loans by Gross Annual Revenue Category

Gross Revenue Level

% of Businesses

#

%

$(000s)

%

<=$1,000,000

89.1

24

96.0

2,389

92.3

>$1,000,000

3.3

1

4.0

200

7.7

Revenue Not Available

7.6

0

0.0

0

0.0

Total

100.0

25

100.0

2,589

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%


Home Mortgage Loans

CSB’s performance in extending home mortgage loans to borrowers of differing income levels is reasonable. As shown in the following table, CSB’s lending performance to low-income borrowers is modestly below aggregate data, while the bank’s performance to moderate-income borrowers is lower than aggregate. Although a slight decline was noted for moderate-income borrowers, improved performance was shown for low-income borrowers when compared to the last evaluation.

Examiners considered other factors when evaluating CSB’s home mortgage performance. HMDA aggregate lending data for 2022 shows that competition for mortgage lending in the assessment area is highly prevalent, with 231 financial institutions originating 10,719 loans in the assessment area.


CSB’s market share of home mortgage loans in the assessment area is 0.97 percent of the total market. Management stated that the institution’s business focus in this assessment area is primarily commercial in nature, not home mortgage lending. This is reflected in the bank’s reported data as the percentage of loans by number in which income information was not available (44.2 percent) and likely skews the data in all borrower income levels, including low- and moderate-income. These loans reflect HMDA- reportable transactions that are not subject to income reporting requirements, such as multi-family dwellings or loans to non-natural persons.


Distribution of Home Mortgage Loans by Borrower Income Level


Borrower Income Level


% of Families

Aggregate Performance

% of #


#


%


$(000s)


%

Low

18.6

11.8

9

8.7

675

4.5

Moderate

19.0

22.5

14

13.5

1,243

8.4

Middle

22.7

21.0

13

12.5

1,414

9.5

Upper

39.8

26.2

22

21.2

5,697

38.3

Not Available

0.0

18.5

46

44.2

5,830

39.2

Totals

100.0

100.0

104

100.0

14,859

100.0

Source: 2020 U.S. Census; Bank Data; 2022 HMDA Aggregate Data. Due to rounding, totals may not equal 100.0%

COMMUNITY DEVELOPMENT TEST

CSB’s community development performance demonstrates adequate responsiveness to community development needs in the Cedar Rapids Metro Assessment Area, considering the institution’s capacity, as well as the need and availability of such community development opportunities.


Community Development Loans

The bank originated 15 community development loans totaling more than $3.0 million in this assessment area. One notable example includes loans granted for a new bar and restaurant in Cedar Rapids, which promoted economic development through job creation for low- and moderate-income individuals.


Qualified Investments

The bank made 26 qualified investments totaling approximately $258,000 in the Cedar Rapids Metro Assessment Area that received consideration during this evaluation. When considering the community contact’s comments regarding rising home prices, one particularly responsive example includes a donation to an organization with a primary purpose of building and rehabilitating affordable housing for low- and moderate-income individuals and families in the Cedar Rapids area.


Community Development Services

The bank received consideration for 14 community development services, which consisted of bank employees providing financial expertise to organizations promoting affordable housing, community services, and economic development efforts within assessment area. A responsive example


includes an employee that provides financial expertise to assist a local school in issuing grants, scholarships, and school necessities for low- and moderate-income families.


DUBUQUE METRO ASSESSMENT AREA – Limited-Scope Review

DESCRIPTION OF INSTITUTION’S OPERATIONS IN THE DUBUQUE METRO ASSESSMENT AREA

The Dubuque Metro Assessment Area includes census tracts 102.01, 102.02, 104, and 105 in western Dubuque County, which comprises the Dubuque, Iowa MSA. According to 2020 U.S. Census data, the assessment area consists of three middle- and one upper-income census tracts. Within the assessment area, the bank operates one full-service office. Examiners noted community development opportunities to be limited given the small and rural nature of the assessment area.

The table below illustrates select demographic characteristics of the Dubuque Metro Assessment Area.


Demographic Information of the Assessment Area

Demographic Characteristics

#

Low

% of #

Moderate

% of #

Middle

% of #

Upper

% of #

NA*

% of #

Geographies (Census Tracts)

4

0.0

0.0

75.0

25.0

0.0

Population by Geography

19,784

0.0

0.0

66.3

33.7

0.0

Housing Units by Geography

7,603

0.0

0.0

69.2

30.8

0.0

Owner-Occupied Units by Geography

6,134

0.0

0.0

69.2

30.8

0.0

Occupied Rental Units by Geography

1,092

0.0

0.0

77.0

23.0

0.0

Vacant Units by Geography

377

0.0

0.0

46.4

53.6

0.0

Businesses by Geography

2,590

0.0

0.0

68.3

31.7

0.0

Farms by Geography

307

0.0

0.0

83.7

16.3

0.0

Family Distribution by Income Level

5,274

15.9

16.6

26.5

41.0

0.0

Household Distribution by Income Level

7,226

19.1

13.8

19.6

47.6

0.0

Median Family Income - Dubuque, Iowa MSA

$82,099

Median Housing Value

$205,694

Median Gross Rent

$794

Families Below Poverty Level

5.5%

Source: 2020 U.S. Census and 2023 D&B Data. (*) The NA category consists of geographies that have not been assigned an income classification. Due to rounding, totals may not equal 100.0%


CONCLUSIONS ON PERFORMANCE CRITERIA IN THE DUBUQUE METRO ASSESSMENT AREA

For evaluation purposes, examiners compared the performance of the Dubuque Metro Assessment Area to the other metropolitan assessment area within the State of Iowa that was reviewed using full-scope examination procedures. For this evaluation, that is the Cedar Rapids Metro Assessment Area.


LENDING TEST

CSB’s lending performance in the Dubuque Metro Assessment Area is consistent with the lending performance of the full-scope assessment area. The following tables demonstrate the bank’s Borrower Profile performance. The Dubuque Metro Assessment Area has no low- or moderate-income census tracts; therefore, the Geographic Distribution criterion was not evaluated for this assessment area.


Borrower Profile

 

Small Farm Loans

 

Distribution of Small Farm Loans by Gross Annual Revenue Category

Gross Revenue Level

% of Farms

#

%

$(000s)

%

<=$1,000,000

98.7

18

90.0

1,472

90.7

>$1,000,000

0.7

1

5.0

50

3.1

Revenue Not Available

0.7

1

5.0

100

6.2

Total

100.0

20

100.0

1,622

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%

Small Business Loans

 

Distribution of Small Business Loans by Gross Annual Revenue Category

Gross Revenue Level

% of Businesses

#

%

$(000s)

%

<=$1,000,000

90.0

25

89.3

1,571

89.7

>$1,000,000

3.6

3

10.7

180

10.3

Revenue Not Available

6.5

0

0.0

0

0.0

Total

100.0

28

100.0

1,751

100.0

Source: 2023 D&B Data; Bank Data.

Due to rounding, totals may not equal 100.0%

Home Mortgage Loans

Although lending to moderate-income borrowers shows as significantly exceeding aggregate data for 2022, this was deemed an anomaly. Examiners noted 2021 showed more typical patterns and 2023 had nominal activity, resulting in overall reasonable distribution.


Distribution of Home Mortgage Loans by Borrower Income Level


Borrower Income Level


% of Families

Aggregate Performance

% of #


#


%


$(000s)


%

Low

15.9

9.6

2

8.3

181

5.5

Moderate

16.6

19.6

10

41.7

1,194

36.5

Middle

26.5

24.4

5

20.8

730

22.3

Upper

41.0

39.5

1

4.2

55

1.7

Not Available

0.0

7.0

6

25.0

1,110

34.0

Totals

100.0

100.0

24

100.0

3,270

100.0

Source: 2020 U.S. Census; Bank Data; 2022 HMDA Aggregate Data. Due to rounding, totals may not equal 100.0%


COMMUNITY DEVELOPMENT TEST

CSB’s community development performance in the Dubuque Metro Assessment Area is below the community development performance in the full-scope Cedar Rapids Metro Assessment Area; however, it does not change the overall conclusion. During the review period, the institution originated no community development loans or qualified investments. CSB recorded 10 qualified community development service activities in the assessment area during the evaluation period.


APPENDICES

 

INTERMEDIATE SMALL BANK PERFORMANCE CRITERIA

 

Lending Test

The Lending Test evaluates the bank’s record of helping to meet the credit needs of its assessment area(s) by considering the following criteria:

  • The bank’s loan-to-deposit ratio, adjusted for seasonal variation, and, as appropriate, other lending-related activities, such as loan originations for sale to the secondary markets, community development loans, or qualified investments;
  • The percentage of loans, and as appropriate, other lending-related activities located in the bank’s assessment area(s);
  • The geographic distribution of the bank’s loans;
  • The bank’s record of lending to and, as appropriate, engaging in other lending-related activities for borrowers of different income levels and businesses and farms of different sizes; and
  • The bank’s record of taking action, if warranted, in response to written complaints about its performance in helping to meet credit needs in its assessment area(s).


Community Development Test

The Community Development Test considers the following criteria:

  • The number and amount of community development loans;
  • The number and amount of qualified investments;
  • The extent to which the bank provides community development services; and
  • The bank’s responsiveness through such activities to community development lending, investment, and service needs.


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.


American Community Survey (ACS): A nationwide United States Census survey that produces demographic, social, housing, and economic estimates in the form of five year estimates based on population thresholds.


Area Median Income: The median family income for the MSA, if a person or geography is located in an MSA; or the statewide nonmetropolitan median family income, if a person or geography is located outside an MSA.

 

Assessment Area: A geographic area delineated by the bank under the requirements of the Community Reinvestment Act.

Census Tract: A small, relatively permanent statistical subdivision of a county or equivalent entity. The primary purpose of census tracts is to provide a stable set of geographic units for the presentation of statistical data. Census tracts generally have a population size between 1,200 and 8,000 people, with an optimum size of 4,000 people. Census tract boundaries generally follow visible and identifiable features, but they may follow nonvisible legal boundaries in some instances. State and county boundaries always are census tract boundaries.


Combined Statistical Area (CSA): A combination of several adjacent metropolitan statistical areas or micropolitan statistical areas or a mix of the two, which are linked by economic ties.


Community Development: For loans, investments, and services to qualify as community development activities, their primary purpose must:

  • Support affordable housing for low- and moderate-income individuals;
  • Target community services toward low- and moderate-income individuals;
  • Promote economic development by financing small businesses or farms; or
  • Provide activities that revitalize or stabilize low- and moderate-income geographies, designated disaster areas, or distressed or underserved nonmetropolitan middle-income


Community Development Corporation (CDC): A CDC allows banks and holding companies to make equity type of investments in community development projects. Institution CDCs can develop innovative debt instruments or provide near-equity investments tailored to the development needs of the community. Institution CDCs are also tailored to their financial and marketing needs. A CDC may purchase, own, rehabilitate, construct, manage, and sell real property. Also, it may make equity or debt investments in development projects and in local businesses. The CDC activities are expected to directly benefit low- and moderate-income groups, and the investment dollars should not represent an undue risk on the banking organization.


Community Development Financial Institutions (CDFIs): CDFIs are private intermediaries (either for profit or nonprofit) with community development as their primary mission. A CDFI facilitates the flow of lending and investment capital into distressed communities and to individuals who have been unable to take advantage of the services offered by traditional financial institutions. Some basic types of CDFIs include community development banks, community development loan funds, community development credit unions, micro enterprise funds, and community development venture capital funds.


A certified CDFI must meet eligibility requirements. These requirements include the following:

  • Having a primary mission of promoting community development;
  • Serving an investment area or target population;
  • Providing development services;
  • Maintaining accountability to residents of its investment area or targeted population through representation on its governing board of directors, or by other means;
  • Not constituting an agency or instrumentality of the United States, of any state or political subdivision of a state.

Community Development Loan: A loan that:

  • Has as its primary purpose community development; and
  • Except in the case of a wholesale or limited purpose institution:
    • Has not been reported or collected by the institution or an affiliate for consideration in the institution’s assessment area as a home mortgage, small business, small farm, or consumer loan, unless it is a multifamily dwelling loan (as described in Appendix A to Part 203 of this title); and
    • Benefits the institution’s assessment area(s) or a broader statewide or regional area including the institution’s assessment area(s).


Community Development Service: A service that:

  • Has as its primary purpose community development;
  • Is related to the provision of financial services; and
  • Has not been considered in the evaluation of the institution’s retail banking services under 345.24(d).


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.


Core Based Statistical Area (CBSA): The county or counties or equivalent entities associated with at least one core (urbanized area or urban cluster) of at least 10,000 population, plus adjacent counties having a high degree of social and economic integration with the core as measured through commuting ties with the counties associated with the core. Metropolitan and Micropolitan Statistical Areas are the two categories of CBSAs.


Distressed Middle-Income Nonmetropolitan Geographies: A nonmetropolitan middle-income geography will be designated as distressed if it is in a county that meets one or more of the following triggers:

  • An unemployment rate of at least 5 times the national average;
  • A poverty rate of 20 percent or more; or
  • A population loss of 10 percent or more between the previous and most recent decennial census or a net migration loss of 5 percent or more over the 5-year period preceding the most recent census.


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 non-relatives living with the family. Families are classified by type as either a married-couple family or other family. Other family 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).


FFIEC-Estimated Income Data: The Federal Financial Institutions Examination Council (FFIEC) issues annual estimates which update median family income from the metropolitan and nonmetropolitan areas. The FFIEC uses American Community Survey data and factors in information from other sources to arrive at an annual estimate that more closely reflects current economic conditions.


Full-Scope Review: A full-scope review is accomplished when examiners complete all applicable interagency examination procedures for an assessment area. Performance under applicable tests is analyzed considering performance context, quantitative factors (e.g, geographic distribution, borrower profile, and total number and dollar amount of investments), and qualitative factors (e.g, 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 (approved, denied, and withdrawn).


Home Mortgage Loans: Includes closed-end mortgage loans or open-end line of credits as defined in the HMDA regulation that are not an excluded transaction per the HMDA regulation.

Housing Unit: Includes a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied as separate living quarters.


Limited-Scope Review: A limited scope review is accomplished when examiners do not complete all applicable interagency examination procedures for an assessment area.


Performance under applicable tests is often analyzed using only quantitative factors (e.g, geographic distribution, borrower profile, total number and dollar amount of investments, and branch distribution).


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.


Low Income Housing Tax Credit: The Low-Income Housing Tax Credit Program is a housing program contained within the Internal Revenue Code of 1986, as amended. It is administered by the U.S. Department of the Treasury and the Internal Revenue Service. The U.S. Treasury Department distributes low-income housing tax credits to housing credit agencies through the Internal Revenue Service. The housing agencies allocate tax credits on a competitive basis.


Developers who acquire, rehabilitate, or construct low-income rental housing may keep their tax credits. Or, they may sell them to corporations or investor groups, who, as owners of these properties, will be able to reduce their own federal tax payments. The credit can be claimed annually for ten consecutive years. For a project to be eligible, the developer must set aside a specific percentage of units for occupancy by low-income residents. The set-aside requirement remains throughout the compliance period, usually 30 years.


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.


Median Income: The median income divides the income distribution into two equal parts, one having incomes above the median and other having incomes below the median.

Metropolitan Division (MD): A county or group of counties within a CBSA that contain(s) an urbanized area with a population of at least 2.5 million. A MD is one or more main/secondary counties representing an employment center or centers, plus adjacent counties associated with the main/secondary county or counties through commuting ties.


Metropolitan Statistical Area (MSA): CBSA associated with at least one urbanized area having a population of at least 50,000. The MSA comprises the central county or counties or equivalent entities containing the core, plus adjacent outlying counties having a high degree of social and economic integration with the central county or counties as measured through commuting.


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 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 and less than 80 percent in the case of a geography.


Multi-family: Refers to a residential structure that contains five or more units.


Nonmetropolitan Area (also known as non-MSA): All areas outside of metropolitan areas. The definition of nonmetropolitan area is not consistent with the definition of rural areas. Urban and rural classifications cut across the other hierarchies. For example, there is generally urban and rural territory within metropolitan and nonmetropolitan areas.


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 lawful investment, deposit, membership share, or grant that has as its primary purpose community development.


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.


Rural Area: Territories, populations, and housing units that are not classified as urban.


Small Business Investment Company (SBIC): SBICs are privately-owned investment companies which are licensed and regulated by the Small Business Administration (SBA). SBICs provide long-term loans and/or venture capital to small firms. Because money for venture or risk investments is difficult for small firms to obtain, SBA provides assistance to SBICs to stimulate and supplement the flow of private equity and long-term loan funds to small companies. Venture capitalists participate in the SBIC program to supplement their own private capital with funds borrowed at favorable rates through SBA’s guarantee of SBIC debentures. These SBIC debentures are then sold to private investors. An SBIC’s success is linked to the growth and profitability of the companies that it finances. Therefore, some SBICs primarily assist businesses with significant growth potential, such as new firms in innovative industries. SBICs finance small firms by providing straight loans and/or equity-type investments. This kind of financing gives them partial ownership of those businesses and the possibility of sharing in the companies’ profits as they grow and prosper.

Small Business Loan: A loan included in “loans to small businesses” as defined in the Consolidated Report of Condition and Income (Call Report). These loans have original amounts of

$1 million or less and are either secured by nonfarm nonresidential properties or are classified as commercial and industrial loans.


Small Farm Loan: 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, including farm residential and other improvements, or are classified as loans to finance agricultural production and other loans to farmers.


Underserved Middle-Income Nonmetropolitan Geographies: A nonmetropolitan middle- income geography will be designated as underserved if it meets criteria for population size, density, and dispersion indicating the area’s population is sufficiently small, thin, and distant from a population center that the tract is likely to have difficulty financing the fixed costs of meeting essential community needs.


Upper-Income: Individual income that is 120 percent or more of the area median income, or a median family income that is 120 percent or more in the case of a geography.


Urban Area: All territories, populations, and housing units in urbanized areas and in places of 2,500 or more persons outside urbanized areas. More specifically, “urban” consists of territory, persons, and housing units in places of 2,500 or more persons incorporated as cities, villages, boroughs (except in Alaska and New York), and towns (except in the New England states, New York, and Wisconsin).


“Urban” excludes the rural portions of “extended cities”; census designated place of 2,500 or more persons; and other territory, incorporated or uni