WASHINGTON, D.C. — The Federal Deposit Insurance Corporation on Friday issued its list of state nonmember banks, including five in Oklahoma, recently evaluated for compliance with the Community Reinvestment Act.
The CRA is a 1977 law that requires the FDIC to assess a bank’s record of meeting the credit needs of its entire community, including those of low- and moderate-income neighborhoods, consistent with safe and sound operations.
A state nonmember bank operates under a state charter and is not a member of the Federal Reserve System, so the FDIC is that institution’s federal regulator, Oklahoma Banking Commissioner Mick Thompson explained.
The latest CRA list covered evaluation ratings the FDIC assigned to institutions in September 2025.
The FDIC examined 58 banks across the nation that month. Of the nearly six dozen banks, all but three received a “satisfactory” rating. Two banks, one in New Mexico and another in Ohio, were informed they “need to improve.”
One bank – Walters Bank and Trust Co., which “has served Cotton County since 1934” – was rated “O” for “outstanding.” A CRA grade of “O” is rare. Southwest Ledger left a message Friday afternoon for Danny Marlett, president of the Walters bank, but he never called back.
The other four Oklahoma banks were Cattlemens Bank in Altus, F&M Bank in Edmond, American Exchange Bank in Lindsay, plus Security Bank and Trust Company in Miami.
An “S” rating means an institution 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 loan-to-deposit ratio is reasonable (considering seasonal variations and taking into account lending-related activities) given the institution’s size, financial condition, and credit needs in the assessment area (AA).
A majority of loans are in the institution’s AA, and the geographic distribution of loans reflects excellent dispersion throughout the AA.
Given the demographics of the assessment area, the distribution of borrowers reflects reasonable penetration among farms and businesses of different sizes, according to the FDIC.