STATEMENT OF THE COMMUNITY REINVESTMENT ACT
August 5, 2024
1. Community Delineation: Our area is described as Census Tract Numbers: 800.01, 800.02,
801.00, 802.01, 802.02, and 803.00 in Ray County, Missouri; census tract 9602.00 (Norborne
Branch) of Carroll County, Missouri; census tract 9602.01, 9602.02 (Main Bank-Lathrop) and
9603.00 Clinton County, Missouri; census tract 9502.01 in Caldwell County, Missouri; census
tract 216.02, 217.01, 217.03, 217.04, 218.06 (Lawson Branch), 218.09, 218.10, 218.11 and
218.12 in Clay County, Missouri; census tract 604.01, 604.02, 605.00, 606.01 (Pleasant Hill
Branch), 606.02, 607.00, 608.00 609.04 and 614.00 Cass County, Missouri.
2. Branch Locations:
Lathrop Facility Lobby Hours 8:30 AM – 4:00 PM, Monday through Friday
Drive-Thru Hours 7:30 AM – 5:00 PM, Monday through Thursday
7:30 AM – 6:00 PM, Friday
7:30 AM – 12:00 PM, Saturday
Lawson Facility Lobby Hours 8:30 AM – 4:00 PM, Monday through Friday
Drive-Thru Hours 7:30 AM – 5:00 PM, Monday through Thurs.
7:30 AM – 6:00 PM, Friday
7:30 AM – 12:00 PM, Saturday
Norborne Facility Lobby Hours 8:30 AM – 4:00 PM, Monday through Friday
Drive-Thru Hours 8:30 AM – 4:00 PM, Monday through Friday
8:30 AM – 12:00 PM, Saturday
Pleasant Hill Facility Lobby Hours 9:00 AM – 5:00 PM, Monday through Friday
9:00 AM – 12:00 PM, SaturdayDrive-Thru Hours 7:00 AM – 5:00 PM, Monday through Thursday
7:00 AM – 6:00 PM, Friday
8:30 AM – 12:00 PM, Saturday
*PLEASANT HILL (SOUTH) LOCATION CLOSED 12/3/2021*
**HOLT LOCATION CLOSED 6/30/2022**
***NEW NORBORNE BANK LOCATION OPENED 6/10/2024***
3. Types of Services Offered (some services vary by location):
DDA Checking Accounts, Interest Bearing Checking Accounts, Savings Accounts, Money Market
Accounts, Certificates of Deposit, IRA’s, Money Orders, Cashier’s Checks, Coin Counter, Fax
Services, Notary Services, Cash Advance Service
Safe Deposit Boxes, Redemption of U.S. Savings Bond, and Account Reconciliation Assistance
Night depository services, Bank-by-Mail, ACH, and EFT Services
Check Cashing for customers
Credit card applications through our Correspondent Bank, (UMB Bank N.A., Kansas City, MO)
Debit Cards; Instant Issue Available
Gift Cards (Non-Reloadable)
Remote Deposit Capture
Mobile Deposit & Mobile App
On-Line Banking, Telephone Banking and Bill Pay Services
Wire Transfers
GFB sponsored Student Focused Bank(s)
ATM Service surcharge free to Goppert Financial Bank’s debit/ATM cardholders at terminals
located at the following locations:
Goppert Financial Bank – 710 Oak Street, Lathrop, MO
Goppert Financial Bank – 29206 NE 184th Street, Lawson, MO
Goppert Financial Bank – 501 Highway 10, Norborne, MO
Goppert Financial Bank – 2100 N State Route 7, Pleasant Hill, MO
Pleasant Hill City Hall – 203 Paul Street, Pleasant Hill, MO
MoneyPass ATM Locations – Visit our website goppertfb.com for a link to a full list of these
locations.
Types of Credit Offered by this Bank: All branch facilities
Commercial Loans – Operating Loans and Lines of Credit, Equipment Loans, Commercial Real
Estate Loans, SBA and USDA Program Loans, Participated in the SBA/PPP Loan Program
Agricultural Loans – Operating Loans and Lines of Credit, Capital Improvement Loans,
Warehouse Receipt Loans, Machinery and Equipment Loans, Livestock Loans, FSA Guaranteed
Loans, FSA Beginning Farmer Loan Program, MO State Beginning Farmer Loan Program, LongTerm Fixed-rate Agricultural Real Estate Loans, Farmer Mac Participating Lender, 4-H & FFA
Loan Program
Consumer Loans – Single payment and installment, including Auto, Boat, Trailer and
Recreational Vehicles
Real Estate Mortgages – Fixed rate mortgages in house through a product offered by FHLB;
Fixed rate mortgages thru Mortgage Investment Services; First-time Home Buyers Programs,
FHA & VA Mortgage Loans – through Mortgage Investment Services
Adjustable-Rate mortgages – In house and Mortgage Investment Services
Construction Loans – In house
Credit Life and Disability Insurance – Sold at Lathrop/Lawson/Norborne/Pleasant Hill
Our Community Reinvestment Act Notice is:
THE FEDERAL COMMUNITY REINVESTMENT ACT (CRA) REQUIRES THE FEDERAL DEPOSIT
INSURANCE CORPORATION (FDIC) TO EVALUATE OUR PERFORMANCE IN HELPING TO MEET
THE CREDIT NEEDS OF THIS COMMUNITY AND TO TAKE THIS EVALUATION INTO ACCOUNT
WHEN THE FDIC DECIDES ON CERTAIN APPLICATIONS SUBMITTED BY US. YOUR
INVOLVEMENT IS ENCOURAGED.
PUBLIC DISCLOSURE
July 24, 2023
COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
Goppert Financial Bank Certificate Number: 8569
710 Oak Street
Lathrop, Missouri 64465
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.
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 area, including low- and moderate-income neighborhoods, in a manner consistent with its resources and capabilities.
The bank’s performance under all applicable criteria supports the overall rating. The following points summarize this performance.
Goppert Financial Bank is a full-service community bank headquartered in Lathrop, Missouri. Goppert Financial Corporation, a two-bank holding company headquartered in Lee’s Summit, Missouri, wholly owns the bank. Goppert Financial Bank received a Satisfactory rating under the Interagency Small Institution Examination Procedures at the prior FDIC performance evaluation dated August 7, 2017.
The bank continues to operate from the main office in Lathrop and branches in Lawson, Norborne, and Pleasant Hill, Missouri. The main office is located in Clinton County, the Lawson branch is in Clay County, the Norborne branch is in Carroll County, and the Pleasant Hill branch is in Cass County. Two branches closed since the previous evaluation: the Holt, Missouri location in Clay County and the Pleasant Hill South location in Cass County, both in Missouri.
Goppert Financial Bank offers agricultural, commercial, home mortgage, and consumer loans, although agricultural lending continues to be the institution’s primary focus. The institution offers government guaranteed loans through the Farm Service Agency. The bank also originated loans under the Small Business Administration’s Paycheck Protection Program (PPP), which was established in 2020 to provide relief financing to small businesses during the Coronavirus Disease 2019 pandemic. The bank originated 150 PPP loans totaling $5.6 million in 2020, and 352 PPP loans totaling $8.2 million in 2021.
The bank provides a variety of deposit services including checking, savings, money market deposit accounts, and certificates of deposits. Alternative banking services include internet banking, mobile banking, telephone banking, and bank-owned ATMs.
According to the March 31, 2023 Reports of Condition and Income, the bank reported total assets of
$259.3 million, total deposits totaling $226.7 million, and total loans totaling $129.2 million. The following table illustrates the loan portfolio.
| Loan Portfolio Distribution as of 3/31/2023 | ||
| Loan Category | $(000s) | % |
| Construction, Land Development, and Other Land Loans | 3,744 | 2.9 |
| Secured by Farmland | 48,048 | 37.2 |
| Secured by 1-4 Family Residential Properties | 13,732 | 10.6 |
| Secured by Multifamily (5 or more) Residential Properties | 757 | 0.6 |
| Secured by Nonfarm Nonresidential Properties | 11,866 | 9.2 |
| Total Real Estate Loans | 78,147 | 60.5 |
| Commercial and Industrial Loans | 24,438 | 18.9 |
| Agricultural Production and Other Loans to Farmers | 25,054 | 19.4 |
| Consumer Loans | 966 | 0.7 |
| Obligations of State and Political Subdivisions in the U.S. | – | – |
| Other Loans | 35 | <0.1 |
| Lease Financing Receivable (net of unearned income) | 624 | 0.5 |
| Less: Unearned Income | 20 | <0.1 |
| Total Loans | 129,244 | 100.0 |
| Source: Reports of Condition and Income | ||
Examiners did not identify any financial, legal, or other impediments that affect the bank’s ability to meet assessment area credit needs.
Goppert Financial Bank has three assessment areas (Lathrop, Cass County, and Carroll County) in Missouri. The census tracts were redrawn since the previous evaluation and the assessment areas were updated to reflect those changes.
According to the 2020 U. S. Census data, the Lathrop assessment area is comprised of 19 census tracts, which are all part of the Kansas City, MO-KS MSA. This assessment area consists of three census tracts in eastern Clinton County, nine census tracts in northeastern Clay County, one census tract in southwestern Caldwell County, and all of Ray County. The second assessment area, Cass County, consists of nine census tracts in northeastern Cass County. The Cass County assessment area is part of the Kansas City, MO-KS MSA. The third assessment area, Carroll County, consists of one census tract in western Carrol County which is located in the non-metropolitan area of Missouri.
The Lathrop and Cass County assessment areas were analyzed and presented together since they are part of the Kansas City, MO-KS MSA and considered homogenous. The combined assessment area is hereby referred to as the MSA Assessment Areas. For further information on the MSA and Carroll County Assessment Areas, refer to the corresponding sections of this evaluation.
Examiners conducted this CRA evaluation using the Interagency Small Institution Examination Procedures. The evaluation covers the period from the prior evaluation dated August 7, 2017, to the current evaluation dated July 24, 2023. Examiners completed a full-scope review for each of the bank’s assessment areas. The MSA Assessment Area received the greater weight in the overall evaluation because that area accounts for the majority of loan originations and deposit business.
Examiners reviewed small farm, small business, and home mortgage loans for this evaluation. Examiners selected these products based on the bank’s business strategy, loan portfolio composition, and the number and dollar volume of loans originated during the evaluation period. Since agricultural lending is the institution’s primary lending focus, the small farm loan category received the most weight when determining overall conclusions for this evaluation.
Due to limited lending levels with different loan types in different assessment areas, not all loan types could be fully analyzed in each assessment area. Specifically, small business and home mortgage loans were not analyzed in the Carroll County Assessment Area because there were too few loans to draw meaningful conclusions (there were 6 small business loans totaling approximately
$600,000 and 1 home mortgage loan totaling approximately $400,000).
For all three loan categories reviewed, examiners focused on loans originated in 2022 since bank management indicated that lending patterns in 2022 are generally representative of the entire review period. Origination activity for 2022 showed 115 small farm loans totaling $14.3 million, 85 small business loans totaling $11.9 million, and 45 home mortgage loans totaling $7.1 million.
For the lending test, examiners reviewed all of these loans for the Assessment Area Concentration analysis. For the Geographic Distribution analysis in the MSA Assessment Area, examiners reviewed all small farm, small business, and home mortgage loans originated inside the assessment area; in the Carroll County Assessment Area, examiners reviewed all small farm loans originated in the assessment area. For the Borrower Profile criterion in the MSA Assessment Area, examiners reviewed a sample of small farm, small business, and home mortgage loans in this assessment area; in the Carroll County Assessment Area, examiners reviewed a sample of small farm loans originated in the assessment area.
2022 D&B data provided a standard of comparison for the bank’s small farm and small business lending performance, and the 2020 U.S. Census data provided a standard of comparison for the bank’s home mortgage lending performance.
LENDING TEST
Goppert Financial Bank demonstrates satisfactory performance under the Lending Test. Performance in all evaluated criteria supports this conclusion. Information on the bank’s overall performance is detailed in this section. Refer to subsequent corresponding sections of this evaluation for detailed information by assessment area.
The loan-to-deposit ratio is reasonable given the institution’s size, financial condition, and assessment area credit needs. The bank’s performance was evaluated based on the average of the 23 quarterly loan-to-deposit ratios since the previous evaluation. The bank’s average net loan-to-deposit (NLTD) ratio of 63.9 percent compares reasonably to similarly situated banks thatwere selected based on their asset size, geographic location, and lending focus. The NLTD fluctuated from a high of 71.5 percent as of September 30, 2017, to a low of 53.5 percent as of March 31, 2022.
The bank’s average NLTD was higher than one of the similar institutions identified, and lower than the other. Examiners considered additional performance context. For example, COVID-19 shelter-in- place mandates and severe weather impacted businesses in the assessment areas during the review period. Ultimately, the retail establishments scaled down on operations and reduced staffing and loan demand. During the evaluation period, the bank participated in the SBA Paycheck Protection Program. The participation in this program coupled with numerous government stimulus payments benefited businesses and consumers, which led to loan payoffs and a significant increase in deposit base. Therefore, considering the resources, competition, and economic factors, the LTD is reasonable. See the following table for details.
| Loan-to-Deposit (LTD) Ratio Comparison | ||
|
Bank |
Total Assets as of 3/31/2023 ($000s) | Average Net LTD Ratio (%) |
| Goppert Financial Bank, Lathrop Missouri | 256,427 | 63.9 |
| Bank Northwest, Hamilton, Missouri | 189,662 | 75.4 |
| Carroll County Trust Company, Carrollton, Missouri | 205,553 | 49.1 |
| Source: Reports of Condition and Income 9/30/2017 – 3/31/2023 | ||
A majority of the small farm, small business, and home mortgage loans were located within the assessment areas. See the following table for details of the distribution of the bank’s lending inside and outside of the assessment areas.
| Lending Inside and Outside of the Assessment Area | ||||||||||
|
Loan Category |
Number of Loans | Dollar Amount of Loans $(000s) | ||||||||
| Inside | Outside | Total | Inside | Outside | Total | |||||
| # | % | # | % | # | $ | % | $ | % | $(000s) | |
| Home Mortgage | 38 | 84.4 | 7 | 15.6 | 45 | 5,893 | 82.5 | 1,247 | 17.5 | 7,140 |
| Small Business | 69 | 81.2 | 16 | 18.8 | 85 | 9,258 | 77.9 | 2,624 | 22.1 | 11,882 |
| Small Farm | 92 | 80.0 | 23 | 20.0 | 115 | 11,065 | 77.4 | 3,232 | 22.6 | 14,297 |
| Total | 199 | 81.2 | 46 | 18.8 | 245 | 26,216 | 78.7 | 7,103 | 21.3 | 33,319 |
| Source: Bank Data | ||||||||||
The geographic distribution of loans reflects reasonable dispersion throughout the MSA Assessment Area. The Carroll County Assessment Area was not reviewed under this criterion as it did not have any low- and moderate-income census tracts.
The distribution of borrowers reflects reasonable penetration among farms and businesses of different revenue sizes and individuals of different income levels. Performance is consistent for both assessment areas. For these analyses, examiners focused on performance in lending to farms and businesses with gross annual revenues of $1 million or less and low- and moderate-income individuals.
The institution has not received any CRA-related complaints since the previous evaluation; therefore, this criterion did not affect the Lending Test rating.
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 discriminatory or other illegal credit practices.
DESCRIPTION OF INSTITUTION’S OPERATIONS IN MSA ASSESSMENT AREA
The MSA Assessment Area includes census tracts 9602.01, 9602.02, and 9603 in Clinton County, census tract 9502.01 in Caldwell County, census tracts 216.02, 217.01, 217.03, 217.04, 218.06,
218.09, 218.10, 218.11, 218.12 in Clay County, all of Ray County, and census tracts 604.01,
604.02, 605, 606.01, 606.02, 607, 608, 609.04, and 614 in Cass County, all in Missouri. The assessment area is part of the Kanas City, MO-KS MSA and consists of both urban population and rural countryside and farmland. The following sections detail demographic and economic information from the 2020 U.S. Census and 2022 D&B data for the assessment area.
The assessment area is comprised of 28 census tracts including 5 moderate-income, 19 middle- income, and 4 upper income. The moderate-income tracts are located in Excelsior Springs in Clay County, Richmond in Ray County, and Harrisonville in Cass County. The majority of the moderate-income tracts are a significant distance from the bank’s branches. The following table illustrates select demographic characteristics of the bank’s MSA Assessment Area.
| Demographic Information of the MSA Assessment Area | ||||||
| Demographic Characteristics | # | Low
% of # |
Moderate
% of # |
Middle
% of # |
Upper
% of # |
NA*
% of # |
| Geographies (Census Tracts) | 28 | 0.0 | 17.9 | 67.9 | 14.3 | 0.0 |
| Population by Geography | 108,657 | 0.0 | 18.1 | 70.7 | 11.2 | 0.0 |
| Housing Units by Geography | 45,340 | 0.0 | 18.4 | 71.2 | 10.4 | 0.0 |
| Owner-Occupied Units by Geography | 31,579 | 0.0 | 13.8 | 72.8 | 13.4 | 0.0 |
| Occupied Rental Units by Geography | 9,748 | 0.0 | 32.3 | 65.3 | 2.4 | 0.0 |
| Vacant Units by Geography | 4,013 | 0.0 | 20.4 | 72.8 | 6.8 | 0.0 |
| Businesses by Geography | 17,534 | 0.0 | 48.0 | 43.3 | 8.7 | 0.0 |
| Farms by Geography | 998 | 0.0 | 20.1 | 69.2 | 10.6 | 0.0 |
| Family Distribution by Income Level | 30,110 | 19.6 | 18.0 | 26.6 | 35.8 | 0.0 |
| Household Distribution by Income Level | 41,327 | 22.9 | 15.9 | 19.4 | 41.8 | 0.0 |
| Median Family Income MSA – 28140 Kansas City, MO-KS MSA | $86,562 | Median Housing Value | $188,314 | |||
| Median Gross Rent | $755 | |||||
| Families Below Poverty Level | 6.2% | |||||
| Source: 2020 U.S. Census and 2022 D&B Data Due to rounding, totals may not equal 100.0%
(*) The NA category consists of geographies that have not been assigned an income classification. |
||||||
According to 2022 D&B data, non-classifiable establishments represent the largest portion of businesses in the assessment area at 37.8 percent; followed by the service industry at 23.5 percent;
and finance, insurance & real estate at 10.4 percent. The data also indicates a notable number of these operations are small, with 54.7 percent of the businesses having four or fewer employees, and 95.8 percent operating from one location.
The following table presents the 2022 Federal Financial Institutions Examination Council (FFIEC) estimated median income levels for the Kansas City, MO-KS MSA. These income levels are used to analyze home mortgage loans under the Borrower Profile criterion.
| Median Family Income Ranges | ||||
| Median Family Incomes | Low
<50% |
Moderate 50% to <80% | Middle 80% to <120% | Upper
≥120% |
| 2022 ($97,300) | <$48,650 | $48,650 to <$77,840 | $77,840 to <$116,760 | ≥$116,760 |
| Source: FFIEC | ||||
Competition of financial services is significant. According to June 30, 2022 FDIC Deposit Market Share Data, there are 42 institutions operating 117 offices within the five counties that are either wholly or partially included in the bank’s assessment area. Of these institutions, Goppert Financial Bank is ranked 15th by market share, with a deposit market share of 1.9 percent. The top five institutions by market share are larger National and regional banks with multiple branches.
A competitive environment exists for small business and home mortgage lending in the assessment area. The 2021 aggregate small business lending data, the most recent data available, reflects 126 lenders originated or purchased 7,930 small business loans. The 2021 aggregate home mortgage lending data reflects 251 lenders originating or purchasing 5,211 home mortgage loans. Goppert Financial Bank is not required to collect or report CRA small business or Home Mortgage Disclosure Act (HMDA) data, but the data is presented to evidence local demand.
Examiners typically contact community members or other third parties in the assessment area to gain insight into the area’s economy, demographic trends, and business environment. This information not only helps in identifying credit and community development needs and opportunities, but also in determining whether local financial institutions are responsive to those needs.
For this examination, examiners utilized two existing contacts that were conducted with community leaders in the assessment area. According to the contacts, small farm lending is the primary need in the more rural portions of the assessment area, while small business and home mortgage lending is the primary need in the more urban portions. Small farm lending demand has increased due to higher input costs as a result of shortages caused by the Russian/Ukraine war. Small business and home mortgage lending had seen increased demand up until the COVID-19 pandemic before leveling off. Small businesses are having trouble retaining employees and housing stock is limited, especially for low- and moderate-income individuals. Both contacts stated that area banks are responsive to the credit needs of the communities that they operate in.
Based on information from the community contact, bank management, and demographic and economic data, examiners determined small farm, small business, and home mortgage loans are all primary credit needs.
LENDING TEST
Goppert Financial Bank demonstrates reasonable performance in this assessment area. Performance under both the Geographic Distribution and Borrower Profile criteria supports this conclusion.
The geographic distribution of loans reflects reasonable dispersion throughout the assessment area. Small farm lending is weighted the heaviest and reflects reasonable dispersion. For this criterion, examiners focused on the percentage, by number, of loans in the assessment area’s moderate-income census tracts.
The geographic distribution of small farm loans reflects reasonable dispersion throughout the MSA Assessment Area. The following table shows that bank lending in moderate-income census tracts lags behind D&B data. As previously mentioned, the bank’s locations are significant distances from the moderate-income census tracts, and all five moderate-income census tracts are within the cities of Excelsior Springs, Harrisonville, and Richmond, which do not offer many farm lending opportunities. The bank’s lending performance is considered reasonable given the location of the offices in relation to the moderate-income census tracts and the limited demand for farm lending in these areas.
| Geographic Distribution of Small Farm Loans | |||||
| Tract Income Level | % of Farms | # | % | $(000s) | % |
| Moderate | 20.1 | 1 | 1.4 | 400 | 4.7 |
| Middle | 69.2 | 68 | 95.8 | 7,626 | 90.5 |
| Upper | 10.6 | 2 | 2.8 | 400 | 4.7 |
| Totals | 100.0 | 71 | 100.0 | 8,426 | 100.0 |
| Source: 2022 D&B Data; Bank Data.
Due to rounding, totals may not equal 100.0% |
|||||
The geographic distribution of small business loans reflects reasonable dispersion throughout the MSA Assessment Area. While the bank’s lending in the moderate-income census tracts lags behind D&B data, the performance is still considered reasonable considering the banking competition in the assessment area and the large agricultural geographic distance between branches as stated above in the competition section. See the table below for details.
| Geographic Distribution of Small Business Loans | |||||
| Tract Income Level | % of Businesses | # | % | $(000s) | % |
| Moderate | 48.0 | 5 | 7.9 | 773 | 8.9 |
| Middle | 43.3 | 52 | 82.5 | 7,345 | 84.7 |
| Upper | 8.7 | 6 | 9.5 | 552 | 6.4 |
| Totals | 100.0 | 63 | 100.0 | 8,670 | 100.0 |
| Source: 2022 D&B Data; Bank Data
Due to rounding, totals may not equal 100.0% |
|||||
The geographic distribution of home mortgage loans reflects reasonable dispersion throughout the MSA Assessment Area. Although the bank did not originate any loans in the moderate-income census tracts, it is still considered reasonable considering the amount of banking competition in the assessment area, as stated above. Additionally, information from one of the community contacts stated that there is a shortage of affordable housing for low- and moderate income individuals, which limits the lending opportunities in the assessment area. See the following table for more details.
| Geographic Distribution of Home Mortgage Loans | |||||
|
Tract Income Level |
% of Owner- Occupied Housing Units |
# |
% |
$(000s) |
% |
| Moderate | 13.8 | 0 | 0.0 | 0 | 0.0 |
| Middle | 72.8 | 34 | 91.9 | 4,465 | 81.8 |
| Upper | 13.4 | 3 | 8.1 | 990 | 18.2 |
| Total | 100.0 | 37 | 100.0 | 5,455 | 100.0 |
| Source: 2020 U.S. Census, Bank Data | |||||
The distribution of borrowers reflects reasonable penetration among farms and businesses of different revenue sizes and individuals of different income levels. This conclusion is supported by the bank’s reasonable performance in small farm, small business, and home mortgage lending categories. For this criterion, examiners focused on the percentage of small farm and small business loans to operations with gross annual revenues of $1 million or less, and the percentage of home mortgage loans to low- and moderate-income borrowers.
The borrower distribution for small farm loans is reasonable. The bank’s lending performance to small farms with revenues of $1 million or less lags D&B data in this revenue category. However, the 2017 Agricultural Census revealed 43.1 percent of farms had revenue of less than $2,500 and 65 percent of farms had no interest expenses. This information indicates a sizeable percentage of farms in the assessment area had little or no need for credit. Refer to the following table for details.
| Distribution of Small Farm Loans by Gross Annual Revenue Category | |||||
| Gross Revenue Level | % of Farms | # | % | $(000s) | % |
| <=$1,000,000 | 98.7 | 26 | 78.8 | 4,879 | 75.6 |
| >$1,000,000 | 0.9 | 6 | 18.2 | 1,375 | 21.3 |
| Revenue Not Available | 0.4 | 1 | 3.0 | 200 | 3.1 |
| Total | 100.0 | 33 | 100.0 | 6,454 | 100.0 |
| Source: 2022 D&B Data, Bank Data. | |||||
The borrower distribution of small business loans is reasonable. The bank’s lending performance to businesses with revenues of $1 million or less lags D&B data in this revenue category. However, for many small businesses, credit needs are often met through credit card and home equity financing, and not all small businesses are seeking traditional financing. Additionally, the competition is extremely high with the number of other lenders competing for the same business within the assessment area. Given the additional performance context factors, the distribution of borrowers reflects reasonable penetration. See the following table for more details.
| Distribution of Small Business Loans by Gross Annual Revenue Category | |||||
| Gross Revenue Level | % of Businesses | # | % | $(000s) | % |
| <=$1,000,000 | 94.3 | 22 | 66.7 | 2,832 | 50.7 |
| >$1,000,000 | 1.6 | 11 | 33.3 | 2,757 | 49.3 |
| Revenue Not Available | 4.1 | 0 | 0.0 | 0 | 0.0 |
| Total | 100.0 | 33 | 100.0 | 5,589 | 100.0 |
| Source: 2022 D&B Data, Bank Data. | |||||
The distribution of home mortgage loans is reasonable. The bank’s lending to low- and moderate- income borrowers is slightly lower than the corresponding demographic data. However, as stated above under the community contact section, there is lack of affordable homes for low- and moderate-income individuals to purchase. In addition, 6.2 percent of the low-income families have income below the poverty level. These families often cannot make the necessary down payment or meet the debt-to-income repayment requirements to qualify for a home mortgage loan. See the following table for more details.
| Distribution of Home Mortgage Loans by Borrower Income Level | |||||
| Borrower Income Level | % of Families | # | % | $(000s) | % |
| Low | 19.6 | 5 | 13.5 | 528 | 9.7 |
| Moderate | 18.0 | 4 | 10.8 | 355 | 6.5 |
| Middle | 26.6 | 7 | 18.9 | 1,273 | 23.3 |
| Upper | 35.8 | 21 | 56.8 | 3,300 | 60.5 |
| Not Available | 0.0 | 0 | 0.0 | 0 | 0.0 |
| Total | 100.0 | 37 | 100.0 | 5,456 | 100.0 |
| Source: 2020 U.S. Census; Bank Data | |||||
DESCRIPTION OF INSTITUTION’S OPERATIONS IN CARROLL COUNTY ASSESSMENT AREA
The Carroll County Assessment Area includes census tract 9602 in Carroll County, Missouri. The assessment area is entirely nonmetropolitan and consists largely of rural countryside and farmland. The following sections detail demographic and economic information from the 2020 U.S. Census and 2022 D&B data for the assessment area.
There are no low- or moderate-income census tracts in the assessment area. The one census tract consists solely of upper-income. The following table show demographic characteristics for the assessment area.
| Demographic Information of the Assessment Area | ||||||
| Demographic Characteristics | # | Low
% of # |
Moderate
% of # |
Middle
% of # |
Upper
% of # |
NA*
% of # |
| Geographies (Census Tracts) | 1 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Population by Geography | 2,419 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Housing Units by Geography | 1,369 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Owner-Occupied Units by Geography | 885 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Occupied Rental Units by Geography | 204 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Vacant Units by Geography | 280 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Businesses by Geography | 230 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Farms by Geography | 99 | 0.0 | 0.0 | 0.0 | 100.0 | 0.0 |
| Family Distribution by Income Level | 797 | 16.1 | 15.1 | 11.5 | 57.3 | 0.0 |
| Household Distribution by Income Level | 1,089 | 12.6 | 12.1 | 18.9 | 56.4 | 0.0 |
| Median Family Income Non-MSAs – MO | $56,957 | Median Housing Value | $108,700 | |||
| Median Gross Rent | $754 | |||||
| Families Below Poverty Level | 12.3% | |||||
| Source: 2020 U.S. Census and 2022 D&B Data Due to rounding, totals may not equal 100.0%
(*) The NA category consists of geographies that have not been assigned an income classification. |
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According to 2022 D&B data, the agriculture industry represents the largest portion of businesses in the assessment area at 30.1 percent, followed by non-classifiable establishments at 23.4 percent, and services at 18.8 percent. The data also indicates a notable number of these operations are relatively small, with 67.2 percent of the businesses having four or fewer employees and 96.1 percent operating from one location.
Competition for financial services is notable. According to June 30, 2022 FDIC Deposit Market Share data, there are 5 banks operating 8 offices within the county that is partially included in the bank’s assessment area. Of these institutions, Goppert Financial Bank ranks 4th in market share with a deposit market share of 12.5 percent. The top 3 institutions by market share are larger regional banks with multiple branches.
Examiners identify the credit needs of the assessment area based on information from the bank management and demographic and economic data. Based on this information, examiners determined small farm, small business, and home mortgage loans are all primary credit needs.
LENDING TEST
Goppert Financial Bank demonstrated reasonable performance under the Lending Test in the Carroll County Assessment Area. Borrower Profile performance, detailed below, supports this conclusion.
The assessment areas do not include any low- and moderate-income geographies, and a review of the Geographic Distribution criterion would not result in meaningful conclusions. Therefore, this criterion was not evaluated.
The distribution of borrowers reflects reasonable penetration among farms of different revenue sizes. Performance for the small farm loan category supports this conclusion. Examiners focused on the percentage of small farm loans to operations with gross annual revenues of $1 million or less. No meaningful conclusions could be drawn regarding the distribution of small business and home mortgage loans given the limited number of loans originated in the assessment area during the review period.
The borrower distribution for small farm loans is reasonable. The bank’s lending performance to small farms with revenues of $1 million or less lags D&B data in this revenue category. However, the 2017 Agricultural Census revealed 38.2 percent of farms had revenue of less than $2,500, and
61.3 percent of farms had no interest expenses. This information indicates a sizeable percentage of farms in the assessment area had little or no need for credit. Refer to the following table for details.
| Distribution of Small Farm Loans by Gross Annual Revenue Category | |||||
| Gross Revenue Level | % of Farms | # | % | $(000s) | % |
| <=$1,000,000 | 98.0 | 15 | 71.4 | 1,126 | 42.7 |
| >$1,000,000 | 2.0 | 6 | 28.6 | 1,513 | 57.3 |
| Revenue Not Available | 0.0 | 0 | 0.0 | 0 | 0.0 |
| Total | 100.0 | 21 | 100.0 | 2,639 | 100.0 |
| Source: 2022 D&B Data, Bank Data. | |||||
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:
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 institution 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.
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.
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.
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.
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 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.
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 unincorporated, including in urbanized areas.
FEES AND CHARGES. The following fees and charges may be assessed against your account:
Check printing fees vary by the style of check ordered.
| Copy Service, each | $0.25 |
| Fax services, 1st page ($.50 each page thereafter) | $2.00 |
| Check copies, each | $2.00 |
| Personal Money Order | $3.00 |
| Cashier’s Check | $6.00 |
| Account Activity printout | $3.00 |
| Copy of Statement | $4.00 |
| Inactive account Fee | $5.00 |
| Dormant account Fee | $10.00 |
| Closing account within 60 days of opening | $15.00 |
| Reopening a closed account | $15.00 |
| Overdraft fee (see Terms and Conditions Overdraft Addendum for complete details) | $30.00 |
| Nonsufficient Funds/Return Item Fee (see Terms and Conditions Overdraft Addendum for complete details) | $30.00 |
| Deposited items returned unpaid (Business and Commercial accounts) | $10.00 |
| Stop Payment | $20.00 |
| Collection Fee (for items sent or held) | $25.00 |
| ATM/Debit Card (Lost or issued before expiration) | $15.00 |
| Incoming Wire Fee (Domestic or International) | $25.00 |
| Outgoing Wire Fee (Domestic) | $30.00 |
| Outgoing Wire Fee (International) | $75.00 |
| Account Research (per Hour) | $50.00 |
| Checkbook Balancing (per Hour) | $50.00 |
| Garnishment/Levy Fee | $50.00 |
| Safe Deposit Box 3×5 (all boxes are subject to Branch availability) | $15.00 |
| Safe Deposit Box 5×5 (Rent is for 12 months) | $20.00 |
| Safe Deposit Box 4×8 | $22.00 |
| Safe Deposit Box 3×10 | $30.00 |
| Safe Deposit Box 4×10 | $40.00 |
| Safe Deposit Box 5×10 | $50.00 |
| Safe Deposit Box 10×10 | $95.00 |
| Safe Deposit Box Key Deposit | $30.00 |
| Safe Deposit Replacement Key | $30.00 |
| Night Depository Replacement Key | $30.00 |
| Gift Cards per card | $4.00 |
Safe Deposit Box drilled or rekeyed – Forfeit deposit plus current cost to the bank.
A late fee of $5.00 per month may be charged on all box sizes if the yearly rent is not paid by the due date.