CRA Public File

As a Texas-based business, Moody National Bank is deeply rooted within its communities. Since the bank's beginnings in 1907 we have been committed to meeting all the financial needs of our customers. Moody National Bank directors and employees live and work in the communities in which we serve, therefore we understand local needs. Whether through in-kind contributions of volunteer hours, or through direct financial support, our giving is based on the belief that our success as a community bank depends on the well-being of our communities. At Moody National Bank, we continue to explore opportunities that will revitalize and stabilize the growth and economic development of the communities in which we serve.

In accordance with the Community Reinvestment Act (CRA) Regulation (Regulation BB, 12 CFR 25) Moody National Bank is required to maintain, and upon request, make available for public inspection a complete CRA Public File.

For your convenience, we've made much of our CRA information available here on our Web site; however, some information cannot be easily captured online. Our Galveston Main Office has a complete CRA file available for public viewing. To obtain information that is not available online, please complete the CRA request form.

Please click on any link below for quick and easy access to the information you are requesting:

CRA Policy | CRA Mission Statement

Assessment Area Tract Listings | Branch/Office/ATM Information

Branches Closed or Opened | Products & Services | Fees

CRA Performance Evaluation | HMDA Disclosure | CRA Disclosure |

Loan to Deposit Ratios

Additional Information in the CRA Public File

CRA Policy


The Community Reinvestment Act (CRA) was enacted as part of the antidiscrimination legislation of the 1970s. Congress ordered that financial institutions must demonstrate that their credit and deposit services are convenient and are meeting the needs of the communities in which they are doing business. The primary focus is to insure that institutions such as ours are reinvesting in their local communities through affirmative credit programs and community involvement.

Changes to CRA were made by the federal banking agencies and were implemented during a two-year period, beginning July 1, 1995 and ending July 1, 1997. These changes reduced the amount of record keeping required while providing more detail on the type of activities necessary to achieve a satisfactory or better CRA rating.

The bank is now evaluated under new lending, investment, and service tests with the greater emphasis on lending. Therefore, this requires expanded data collection and reporting.

Moody National Bank, being a federally regulated institution whose deposits are insured by the FDIC, must comply with the Community Reinvestment Act. To create an enforcement mechanism for CRA, any application for a new charter, deposit insurance, a branch office, relocation of a main office or a branch, merger or acquisition, or the formation of a bank holding company is subject to adequate CRA performance.

Moody National Bank is committed to meeting the requirements of CRA as outlined in this policy. A CRA Officer will be named to be responsible for overall compliance with the act. The CRA Officer must stay abreast of the requirements of the act and update CRA procedures for changes that may be made from time to time.

Delineation of Community

Moody National Bank defines its assessment areas as two (2) separate local communities. The primary Assessment Area would be all our offices, branches and ATM's located in Galveston, Brazoria, Harris, and Fort Bend Counties. The Bank's second Assessment Area would be our offices, branches and ATM's located in Travis County.

The assessment areas delineated by Moody National Bank represent the communities we serve; each is listed below. A map as well as a list of the individual tracts that make up an assessment area can be viewed by clicking the links related to the assessment area of your choice.

Assessment Area 1

Brazoria - Map - Geographies/Tracts

Fort Bend - Map - Geographies/Tracts

Galveston - Map - Geographies/Tracts

East Harris - Map - Geographies/Tracts

West Harris - Map - Geographies/Tracts

Assessment Area 2

Travis County - Map - Geographies/Tracts

Annual Review

It is the responsibility of the CRA Officer to conduct a review of CRA policies and procedures prior to April 1 of each year. This review should determine that the bank is in compliance with the requirements of the act and that the delineation of the community is stated correctly for the bank's marketing area.

The lending test evaluates a bank's record of helping to meet the credit needs of its assessment area through its lending activities by considering a bank's home mortgage, small business, small farm, and community development lending. Performance criteria is evaluated according to geographic distribution, the portion of the bank's lending in the bank's assessment area, the dispersion of lending in the bank's assessment area, and the number and amount of loans in low-, moderate-, middle-, and upper-income geographies in the bank's assessment area.

The investment test evaluates a bank's record of helping to meet the credit needs of its assessment area through qualified investments that benefit the assessment area or broader statewide or regional area that includes the bank's assessment area. The OCC evaluates the investment performance of a bank pursuant to the dollar amount of qualified investments, the innovativeness or complexity of qualified investments, the responsiveness of qualified investments to credit and community development needs, and the degree to which qualified investments are not routinely provided by private investors.

The service test evaluates a bank's record of helping to meet the credit needs of its assessment area by analyzing both the availability and effectiveness of a bank's system for delivering retail banking services and the extent and innovativeness of its community development services. Community development services must benefit a bank's assessment area or a broader statewide or regional area that includes the bank's assessment area. The OCC evaluates the availability and effectiveness of a bank's system for delivering retail banking services based on the current distribution of the bank's branches among low-, moderate-, and upper-income geographies, the bank's record of opening and closing branches (particularly branches located in low-or moderate-income areas), the availability and effectiveness of alternative systems for delivering retail banking services (e.g. ATM's, banking by phone or computer, and bank by mail programs) in low- and moderate-income areas and to low- and moderate-income individuals, and the range of services provided in low-, moderate-, middle-, and upper-income geographies and the degree to which the services are tailored to meet the needs of those geographies.

Public File

We will establish and maintain a CRA file at the main office that is readily available for public review. It will include:

[1] Any signed, written comment letters received from the public during the current year and the two prior years that specifically relate to our CRA performance and any responses to those written comments.

[2] A copy of the public section of the bank's most recent CRA Performance Evaluation prepared by the OCC. This must be placed in the file within 30 business days after receipt from the OCC.

[3] A map of the assessment area that identifies the census tracts included in the assessment area or that is accompanied by a list of census tracts.

[4] A list of the bank's branches, their street address, and the census tracts in which they are located.

[5] A list of branches opened or closed within the current year and each of the two prior years, their street addresses, and the census tracts in which they are or were located.

[6] A list of the services generally offered at the bank's branches (including hours of operation, available loan and deposit products, and transaction fees) and descriptions of any material deviations in the availability or cost of services at particular branches, if any. A description of alternative systems for delivering retail-banking services, such as ATMs, hot line; Home Banking, etc. will also be provided.

[7] The Bank's loan-to-deposit ratio for each quarter of the prior calendar year.

[8] The banks CRA Disclosure Statement which shall be placed in the public file within three business days of its receipt from the OCC.

If you would like to review information about our CRA Performance, the CRA Public File is available at the following location: 2302 Postoffice Street, Galveston, TX 77550. Additional information is available by request through our branches or online via email from our CRA Officer Alice Gary, at* This information will be provided to you within five calendar days after you make the request.

*Do not send information you consider confidential via email as it will not be transmitted through a secure line. Instead, please speak to Customer Service or visit your local branch.

Lobby Notice

There will be a Community Reinvestment Act Notice posted at the main office and at each branch location that complies with the act.

Employee Participation

By adoption of this policy The Board and Bank Management encourage all officers and employees to be active in community activities and to apprise Bank Management of any credit or banking needs they know of in our community and in particular the needs of various low and moderate income groups. Bank employees are expected to cooperate with and carry out the provisions of this CRA Policy.

Public Evaluation

The public section shall state the findings and conclusions of the regulatory agency concerning our institution's compliance with the Community Reinvestment Act. The evaluation must discuss the facts supporting the conclusions and contain our CRA rating. The CRA rating will be listed as one of the following:

1. Outstanding

2. Satisfactory

3. Needs to improve

4. Substantial noncompliance


There is no civil or criminal liability in the Community Reinvestment Act. Rather, administrative enforcement is found through the denial of applications for new branches, formation of bank holding companies, acquisitions & mergers, and offsite ATMs.

CRA Mission Statement

Moody National Bank is committed to its communities and its desire to extend credit to and to participate in community development programs designed to meet the credit needs of all community members, including those in low-and moderate-income areas.

  • We will actively seek to understand the credit needs of our community.
  • We will actively strive to ensure that our products and services are responsive of the needs of the customers within our communities.
  • We will actively strive to ensure that all potential customers in our communities, including those in low- and moderate-income areas, are fully aware of the services we offer and our desire to serve their financial needs.
  • We will actively work to ensure that our employees understand and share the bank's commitment to providing service to all our customers and are provided with the knowledge, products delivery systems, and motivation to do so effectively.