COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION
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 RATING
INSTITUTION'S CRA RATING: This institution is rated Satisfactory. its resources and capabilities.
The loan-to-deposit ratio is reasonable given the institution's size, financial condition, and assessment areas credit needs.
The bank made a majority of the loans reviewed inside the bank's assessment areas.
The bank's geographic distribution of loans reflects a reasonable dispersion throughout the assessment areas.
The bank's distribution of borrowers reflects a reasonable penetration of loans to businesses of different sizes and individuals of different income levels.
The bank has not received any Community Reinvestment Act (CRA)-related complaints since the previous evaluation. Therefore, this factor did not affect the Lending Test rating.
DESCRIPTION OF INSTITUTION
Bank of the Lowcountry is a state-chartered, non-member, community bank headquartered in Walterboro, Colleton County, South Carolina (SC). The bank is wholly-owned by Communitycorp, a single-bank holding company also located in Walterboro, SC. Bank of the Lowcountry does not own any operating subsidiaries, nor does it have any other affiliate interests. The bank received a Satisfactory rating at its previous FDIC CRA Performance Evaluation, dated January 19, 2016, which was based on Interagency Small Institution Examination Procedures.
The bank currently operates five full-service offices in three counties in the eastern portion of South Carolina. The bank operates its main office and one branch in Walterboro, Colleton County; one branch in Ridgeland, Jasper County; one branch in Ravenel, Charleston County; and, one branch in Mount Pleasant, Charleston County. The Mount Pleasant branch was opened on January 6, 2020, and is a new addition since the previous evaluation. The bank has not closed any offices nor has it participated in any merger or acquisition activity since the previous evaluation.
The bank is primarily a commercial lender, which has not changed since the previous evaluation. In addition to commercial loans, the bank offers home mortgage, agricultural/farm, and consumer loans. The bank provides a variety of deposit products including checking, savings, certificates of deposit, and individual retirement accounts. Additionally, the bank offers alternative services, which include internet banking, mobile banking, and access to automated teller machines (ATMs). Non-deposit taking ATMs are located at each office, except for the Forrest Hills branch in Walterboro, SC, and at five remote locations throughout Walterboro, SC. Two of the five remote ATMs were opened since the previous evaluation.
As of the December 31, 2021 Consolidated Reports of Condition and Income, the bank had total assets of $297.4 million, total loans of $119.9 million, total deposits of $259.1 million, and total securities of $87.7 million. As shown in the following table, commercial loans (loans secured by non-farm, nonresidential properties and commercial and industrial loans) represent the largest portion of the loan portfolio at 38.6 percent, followed by loans secured by 1-4 family residential properties at 25.8 percent and construction loans at 14.7 percent.
Loan Portfolio Distribution as of 12/31/2021
| Loan Category | $(000s) | % |
|---|---|---|
| Construction, Land Development, and Other Land Loans | 17,574 | 14.7 |
| Secured by Farmland | 5,160 | 4.3 |
| Secured by 1-4 Family Residential Properties | 30,992 | 25.8 |
| Secured by Mulifamily (S or more) Residential Properties | 11,854 | 9.9 |
| Secured by Nonfar Nonresidential Properties | 4,323 | 28.6 |
| Total Real Estate Loans | 99,903 | 83.3 |
| Commercial and Industrial Loans | 11,983 | 10.0 |
| Agriculture Production and Other Loans Farmers | 4,834 | 4.0 |
| Consumer Loans | 2,687 | 2.2 |
| Obligations of States and Political Subdivisions in the U.S. | 53 | 0.5 |
| Total Loans | 119,943 | 100.0 |
Source: Reports of Condition and Income
Examiners did not identify any financial or legal impediments, other than legal lending limits, that would affect the bank's ability to meet the credit needs of its assessment areas.
DESCRIPTION OF ASSESSMENT AREAS
The CRA requires each financial institution to define one or more assessment areas within which its CRA performance will be evaluated. Bank of the Lowcountry has designated three assessment areas, all within the State of South Carolina. Two of the assessment areas are located in metropolitan statistical areas (MSAs) and one is located in a non-MSA (NMSA). The assessment areas include Colleton County, which is in the SC NMSA; Charles County, which is in the Charleston-North Charles, SC MSA; and Jasper County, which is in the Hilton Head Island-Bluffton, SC MSA.
The following table details the counties, number of census tracts (CTs), and branches included in each assessment area for the current evaluation. Refer to the Description of Institution's Operations in each assessment area section of this evaluation for additional information.
Description of Assessment Areas at the Current Performance Evaluation
| Assessment Area | Counties in Assessment Area | # of CTs | # of Branches |
|---|---|---|---|
| NMSA | Colleton | 10 | 2 |
| Charleston-North Charleston, SC MSA (Charleston MSA) |
Charleston | 86 | 2 |
| Hilton Head Island-Bluffton, SC MSA (Hilton Head Island MSA) |
Jasper | 5 | 1 |
Source: Bank Data
SCOPE OF EVALUATION
General Information
This evaluation covers the period from the prior evaluation dated January 19, 2016, to the current evaluation dated January 31, 2022. Examiners used the Interagency Small Institution Examination Procedures to evaluate the bank's CRA performance. These procedures include the CRA Small Bank Lending Test.
Full-scope analyses were conducted for the MSA and Charleston MSA Assessment Areas. Limited-scope analysis was conducted for the Hilton Head Island MSA Assessment Area because f the relatively limited level of lending activities in the area. Examiners gave more weight to banl ictivities in the NMSA Assessment Area due to the level of lending and deposit activity and branching structure therein, followed by the Charleston MSA Assessment Area, and then the Hilton Head Island MSA Assessment Area. The table below details the breakdown of loans, deposits, and offices by assessment area.
Assessment Area Breakdown of Loans, Deposits, and Branches
| Assessment Area | Loans $(000s) |
Loans % |
Deposits $(000s) |
Deposits % |
Branches # |
Branches % |
|---|---|---|---|---|---|---|
| NMSA | 7,848 | 43.5 | 172,930 | 68.3 | 2 | 40.0 |
| Charleston MS | 9,823 | 54.4 | 38,706 | 15.3 | 2 | 40.0 |
| Hilton Head Island MS | 389 | 2.1 | 41,671 | 16.4 | 1 | 20.0 |
| Total | 18,060 | 100.0 | 253,307 | 100.0 | 5 | 100.0 |
Source: Bank Data: FDIC Summary of Deposits (06/30/2021
Although the dollar amount of lending is greater in the Charleston MSA Assessment Area, the majority of loans by number were originated in the NMSA Assessment Area as shown in the table below.
Small Business and Home Mortgage Lending Activity by Assessment Area
| Assessment Area | # | % | $(000s) | % |
|---|---|---|---|---|
| NMSA | 124 | 77.0 | 7,848 | 43.5 |
| Charleston MSA | 31 | 19.3 | 9,823 | 54.4 |
| Hilton Head Island MSA | 6 | 3.7 | 389 | 2.1 |
| Total Loans | 161 | 100.0 | 18,060 | 100.0 |
Source: Bank Data
Activities Reviewed
Examiners determined the bank's major product lines are small business and home mortgage loans. This conclusion considered the bank's business strategy and the distribution of the loan portfolio. No other loan types, such as small farm or consumer loans, represent a major product line. Therefore, they provided no material support for conclusions or ratings and are not presented Small business loans received greater weight in determining the overall rating given the level of loans originated and reviewed by product type, as shown in the following table.
Loan Products Reviewed
| Loan Category | Universe # |
Universe $(000s) |
Reviewed # |
Reviewed $(000s) |
|---|---|---|---|---|
| Home Mortgage 2021 | 45 | 11,933 | 45 | 11,933 |
| Small Business 2021 | 162 | 12,983 | 162 | 12,983 |
| Total | 207 | 24,916 | 207 | 24,916 |
For the Lending Test examiners reviewed the number and dollar volume of small business and home mortgage loans. While the number and dollar volume of loans are presented, examiners emphasized performance by number of loans because the number of loans is a better indicator of the number of businesses and individuals served.
Examiners reviewed the universe of small business loans for 2021, which includes 73 loans originated under the Small Business Administration's Paycheck Protection Program (PPP) totaling $2.5 million. The universe of small business loans was used to evaluate the bank's Assessment Area Concentration performance. Only small business loans originated within the assessment areas was used to evaluate the Geographic Distribution and Borrower Profile performance. D&B data for 2021 provided the standards of comparison for small business loans.
The bank is not a Home Mortgage Disclosure Act (HMDA) reporter. Therefore, examiners reviewed the universe of home mortgage loans for 2021. The universe of home mortgage loans was to evaluate the bank's Assessment Area Concentration. Only home mortgage loans originated within the assessment areas was used to evaluate for Geographic Distribution and Borrower Profile performance. The 2015 American Community Survey (ACS) data, the percentage of owner-occupied housing units by geography, and the percentage of families by income level were used for comparison purposes, respectively.
According to management, the bank's 2021 small business and home mortgage lending activities and performance are representative of the its activities and performance during the entire period since the previous evaluation.
CONCLUSIONS ON PERFORMANCE CRITERIA
LENDING TEST
Bank of the Lowcountry demonstrated reasonable performance under the Lending Test. The loan-to deposit ratio, assessment area concentration, geographic distribution, and borrower profile performance support this conclusion.
Loan-to-Deposit Ratio
Bank of the Lowcountry's net loan-to-deposit (NLTD) ratio is reasonable, given the bank's size, financial condition, and assessment areas' credit needs. The bank's average NLTD ratio of 53.1 percent was calculated using the 24 quarter-end LTD ratios since the prior evaluation. The quarterly NLTD ratios ranged from a high of 65.6 percent on June 30, 2019, to a low of 43.1 percent on September 30, 2021.
The bank has several competitors, but none are similarly situated in terms of total assets, markets served, products offered, and office locations. As a result, the bank's average LTD ratio was compared to that of a peer group as defined by the Uniform Bank Performance Report (UBPR), which includes insured commercial banks with total assets of $100 million and $300 million, with three or more full service banking offices. The UBPR Peer Group's average LTD ratio, calculated over the same 24 quarters, was 74.8 percent and is 21.7 percentage points higher than Bank of the Lowcountry's average NLTD ratio. The UBPR Peer Group's NLTD ratios ranged from a high of 79.8 percent on September 30, 2018, to a low of 63.5 percent on December 31, 2021.
The bank's lending performance is reasonable given that it services local government transaction accounts, which may inflate the amount of deposits, thereby negatively affecting the LTD ratio. Municipal or public funds made up 13.0 percent of total deposits as of December 31, 2021. Additionally, lack of loan demand given lagging economic conditions, especially in the rural areas of the bank's assessment areas, and significant competition has limited the bank's lending opportunities during the evaluation period.
Assessment Area Concentration
A majority of loans were originated in the bank's assessment areas. See the below table for details.
Lending Inside and Outside of the Assessment Areas
| Number of Loans | Dollar Amount of Loans S(000s | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Loan Category | Inside # | Inside % | Outside # | Outside % | Total # | Inside # | Inside % | Outside # | Outside % | Total $(000s) |
| Home Mortgage | 37 | 82.2 | 8 | 17.8 | 45 | 10,294 | 86.3 | 1,639 | 13.7 | 11,933 |
| Small Business | 124 | 76.5 | 38 | 23.5 | 162 | 7,766 | 59.8 | 5,217 | 40.2 | 12,983 |
| Total | 161 | 77.8 | 46 | 22.2 | 207 | 18,060 | 72.5 | 6,856 | 27.5 | 24,916 |
Source: Bank Data
Geographic Distribution
Overall, the geographic distribution of loans reflects reasonable dispersion throughout the assessment areas. Reasonable lending performance throughout the Charleston MSA Assessment Area supports this conclusion. The NMSA Assessment Area does not contain low- or moderate-income census tracts, and the Hilton Head Island MSA Assessment Area does not include any low-income geographies and had limited lending activity. Therefore, a review of the Geographic Distribution criterion in these assessment areas would not result in meaningful conclusions.
Borrower Profile
The distribution of loans to borrowers reflects, given the demographics of the assessment areas, an overall reasonable penetration among businesses of different sizes and individuals of different income levels, including low- and moderate-income individuals. Reasonable lending performance the NMSA and Charleston MSA Assessment Areas supports this conclusion. The Hilton Head Island MSA Assessment Area had limited activity: therefore, a review of the Borrower Profile criterion in this assessment area would not result in meaningful conclusions.
Response to Complaints
The bank has not received any CRA-related complaints since the previous evaluation. Therefore, this criterion did not affect the Lending Test rating.
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 Equal Credit Opportunity Act. Examiners did not identify any discriminatory or other illegal credit practices.
NSA ASSESSMENT AREA - Full-Scope Review
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE NMSA ASSESSMENT AREA
The Non-MSA Assessment Area consists of Colleton County in its entirety. The bank operates 2, or 40.0 percent, of its branch offices in the NMSA Assessment Area. The assessment area accounts for 43.5 percent of total loans by dollar and 68.3 percent of deposits bank-wide.
Economic and Demographic Data
The NMSA Assessment Area is comprised of 10 census tracts, including eight middle-, one upper-income, and one census tract that has not been assigned an income classification (NA). The income classifications for this assessment area changed from the previous evaluation where there were three moderate, five middle-, one upper-income, and one NA census tract, given the changes that resulted from the 2015 ACS. Both offices are located in distressed and/or underserved middle-income census tracts. The following table presents demographic information from the 2015 ACS census and 2021 D&B data.
Demographic Information of the Assessment Area
Assessment Area: NMSA
| Demographic Characteristics | # | Low % of # | Moderate % of # | Middle % of # | Upper % of # | NA* % of # |
|---|---|---|---|---|---|---|
| Geographies (Census Tracts) | 10 | 0.0 | 0.0 | 80.0 | 10.0 | 10.0 |
| Population by Geography | 38,004 | 0.0 | 0.0 | 94.1 | 5.9 | 0.0 |
| Housing Units by Geography | 19,749 | 0.0 | 0.0 | 84.1 | 15.9 | 0.0 |
| Owner-Occupied Units by Geography | 10,844 | 0.0 | 0.0 | 93.0 | 7.0 | 0.0 |
| Occupied Rental Units by Geography | 3,930 | 0.0 | 0.0 | 96.3 | 3.7 | 0.0 |
| Vacant Units by Geography | 4,975 | 0.0 | 0.0 | 55.0 | 45.0 | 0.0 |
| Businesses by Geography | 2,520 | 0.0 | 0.0 | 92.3 | 7.7 | 0.0 |
| Farms by Geography | 139 | 0.0 | 0.0 | 91.4 | 8.6 | 0.0 |
| Family Distribution by Income Level | 9,859 | 23.1 | 20.3 | 17.5 | 39.1 | 0.0 |
| Household Distribution by Income Level | 14,774 | 24.5 | 17.5 | 18.2 | 40.0 | 0.0 |
| Median Family Income Non-MSAs - SC | $44,609 | Median Housing Value Median Gross Rent Families Below Poverty Level |
$111,175 $683 17.5% |
|||
Source: 2015 ACS and 2021 D&B Data, Due to rounding, totals may not equal 100.0%, (*) The N1 category consists of geographies that have not been assigned an income classification.
During 2021, all eight middle-income census tracts in the bank's NMSA Assessment Area were designated as distressed and/or underserved geographies (i.e., census tracts) based on high poverty levels.
Based on the 2021 D&B data, the gross annual revenues (GARs) for business in the assessment area are:
83.5 percent have $1 million or less;
3.4 percent have more than $1 million; and,
13.1 percent have unknown revenues.
In 2021, the top industries in the NMSA Assessment Area were services, followed by retail trade, non-classified establishments, and construction. Top area employers include the Colleton County School District, Colleton County Government, Colleton Medical Center, and Wal-Mart Associates, Inc.
According to the Bureau of Labor Statistics, unemployment rates in the assessment area declined between 2018 and 2019, increased in 2020 due to the COVID Pandemic, and declined again during 2021. The following table reflects the unemployment rates and trends for the assessment area, State of South Carolina, and nation during the period.
Unemployment Rates - NMSA Assessment Area
| Area | 2018 % | 2019 % | 2020 % | November 2021 % |
|---|---|---|---|---|
| Colleton County | 3.9 | 3.1 | 6.1 | 3.2 |
| South Carolina | 3.4 | 2.8 | 6.2 | 3.5 |
| National Average | 3.9 | 3.7 | 8.1 | 3.9 |
Source: Bureau of Labor Statistics
Competition
The NMSA Assessment Area is moderately competitive in the financial services market. The FDIC's June 30, 2021 Summary of Deposits revealed that seven FDIC-insured institutions operated 12 offices within this assessment area. Of these institutions, Bank of the Lowcountry ranked first, with a 28.9 percent deposit market share. The top three financial institutions accounted for 85.3 percent of the deposit market share and include South State Bank, 1st Federal Savings Bank of SC, and Enterprise Bank of SC.
Community Contact
As part of the evaluation process, examiners contact third parties active in the assessment area to assist in identifying area credit and community development needs. This information helps determine whether local financial institutions are responsive to these needs. It also shows what credit and community development opportunities are available.
Examiners contacted a representative of a non-profit economic development organization operating within Colleton County. The organization works to manage and promote economic development in the county to create quality jobs, improve per capita income, and broaden the tax base. The contact indicated that economic conditions continue to lag when compared to surrounding areas and that the ongoing pandemic has negatively impacted the county over the past several years. The contact indicated the financing for small businesses and residential development within the county, particularly with respect to affordable housing, are ongoing needs.
Credit Needs
Considering demographic and economic data, examiners determined that small business loans represent a primary credit need of the assessment area. The significant percentage of businesses with gross annual revenues of $1 million or less; the large number of businesses with four or fewer employees; and the information obtained from the community contact support the conclusion that there is a need for small business lending. The contact also indicated that affordable housing represents a need, as 43.4 percent of the families are low- or moderate-income.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE NMSA ASSESSMENT AREA
LENDING TEST
Bank of the Lowcountry's lending performance within the NMSA Assessment Area reflects satisfactory performance. The bank's Borrower Profile performance supports this conclusion.
Lending in the NMSA Assessment Area represents 79.0 percent by number and 72.8 by dollar volume of small business loans and 70.3 percent by number and 21.3 by dollar volume of home mortgage loans institution-wide.
Geographic Distribution
As previously noted, the NMSA Assessment Area does not include any low- or moderate-income geographies, and a review of the Geographic Distribution criterion would not result in meaningful conclusions. Therefore, this criterion was not evaluated.
Borrower Profile
The distribution of borrowers reflects reasonable penetration among businesses of different sizes and borrowers of different income levels within the assessment area. Reasonable lending performance for small business and home mortgage loans supports this conclusion.
Small Business Loans
The distribution of small business loans reflects reasonable penetration among businesses of different sizes within the NMSA Assessment Area. As reflected in the following table, the bank's lending to businesses with GARs of $1 million or less was 40.6 percent below demographics. However, it is important to consider that 45 of the loans, or 45.9 percent, are PPP loans where revenues were not available for analysis purposes. When considering only loans with available revenue information, lending to small businesses was 79.2 percent, which is comparable to demographics. The following table reflects the distribution of small business loans among businesses of different sizes.
Distribution of Small Business Loans by Gross Annual Revenue Category Assessment Area: NMSA
| Gross Revenue Level | % of Businesses | # | % | $(000s) | % |
|---|---|---|---|---|---|
| <=$1,000,000 | 83.5 | 42 | 42.9 | 1,601 | 28.3 |
| >$1,000,000 | 3.5 | 9 | 9.1 | 2,386 | 42.2 |
| Revenue Not Available | 13.1 | 47 | 48.0 | 1,666 | 29.5 |
| Total | 100.0 | 98 | 100.0 | 5,653 | 100.0 |
Source: 2021 D&B Data, Bank Data. Due to rounding, totals may not equal 100.0%
Examiners also evaluated PPP loans using loan size as a proxy for the size of the business served. A majority of the PPP loans originated in the assessment area, by number, had loan sizes of $100,000 or less, and all PPP loans had loan sizes of $250,000 or less, indicating that the bank is helping to serve the needs of small businesses in the assessment area. The following table reflects the distribution of PPP loans by loan size.
Distribution of PPP Loans by Loan Size Assessment Area: NMSA
| Loan Size | Count | Percent | Dollars (000s) | Percent |
|---|---|---|---|---|
| <$100,000 | 44 | 97.8 | 1,083 | 87.3 |
| $100,000 - $249,999 | 1 | 2.2 | 158 | 12.7 |
| Total | 45 | 100.0 | 1,241 | 100.0 |
Source: 2021 D&B Data, Bank Data.
Home Mortgage Loans
The distribution of home mortgage loans reflects reasonable penetration among borrowers of different income levels. Home mortgage lending to low-income borrowers was 11.5 percent, which is below the percentage of low-income families in the assessment area. This performance is considered reasonable given that 17.5 percent of the assessment area's families live below the poverty level. As a result, these individuals may not have the financial capacity to borrow or likely do not meet the minimum qualification requirements to obtain a loan from a financial institution. Home mortgage lending to moderate-income borrowers was 15.4 percent or 4.9 percent below demographics. The following table reflects the distribution of home mortgage loans to borrowers of different incomes.
Distribution of Home Mortgage Loans by Borrower Income Level Assessment Area: NMSA
| Borrower Income Level | % of Families | # | % | $(000s) | % |
|---|---|---|---|---|---|
| Low | 23.1 | 3 | 11.5 | 128 | 5.8 |
| Moderate | 20.3 | 4 | 15.4 | 222 | 10.1 |
| Middle | 17.5 | 6 | 23.1 | 480 | 21.9 |
| Upper | 39.1 | 11 | 42.3 | 1,172 | 53.4 |
| Not Available | 0.0 | 2 | 7.7 | 193 | 8.8 |
| Total | 100.0 | 26 | 100.0 | 2,195 | 100.0 |
Source: 2015 ACS; Bank Data
CHARLESTON MSA ASSESSMENT AREA - Full-Scope Review
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE CHARLESTON MSA ASSESSMENT AREA
The Charleston MSA Assessment Area consists of Charleston County in its entirety. This assessment area changed, due to the opening of the Mount Pleasant Branch, from the prior evaluation where the assessment area consisted of Charleston and Dorchester Counties. The bank operates two, or 40.0 percent, of its branch offices in the Charleston MSA Assessment Area. The assessment area accounts for 54.4 percent of total loans by dollar amount and 15.3 percent of deposits institution-wide.
Economic and Demographic Data
The Charleston MSA Assessment Area is comprised of 86 census tracts, including 14 low-, 15 moderate-, 23 middle-, 31 upper-income, and 3 NA- census tracts. The area branches are located in a moderate- and upper-income census tract, respectively. The below table presents demographic information from the 2015 ACS and the 2021 D&B data.
Demographic Information of the Assessment Area Assessment Area: Charleston MSA
| Demographic Characteristics | # | Low % of # | Moderate % of # | Middle % of # | Upper % of # | NA* % of # |
|---|---|---|---|---|---|---|
| Geographies (Census Tracts) | 86 | 16.3 | 17.4 | 26.7 | 36.0 | 3.5 |
| Population by Geography | 372,904 | 12.7 | 17.2 | 29.8 | 38.7 | 1.5 |
| Housing Units by Geography | 175,607 | 11.9 | 17.2 | 29.2 | 40.3 | 1.4 |
| Owner-Occupied Units by Geography | 89,750 | 6.4 | 14.8 | 31.4 | 46.9 | 0.5 |
| Occupied Rental Units by Geography | 58,268 | 20.3 | 21.1 | 29.7 | 26.6 | 2.3 |
| Vacant Units by Geography | 27,589 | 11.8 | 17.1 | 20.9 | 47.8 | 2.4 |
| Businesses by Geography | 40,086 | 11.5 | 16.5 | 25.6 | 44.1 | 2.3 |
| Farms by Geography | 904 | 5.6 | 15.3 | 39.0 | 39.3 | 0.8 |
| Family Distribution by Income Level | 87,214 | 22.8 | 15.2 | 17.6 | 44.4 | 0.0 |
| Household Distribution by Income Level | 148,018 | 26.0 | 15.0 | 16.4 | 42.6 | 0.0 |
| Median Family Income MSA - 16700 Charleston-North Charleston, SC MSA | $65,558 | Median Housing Value Median Gross Rent Families Below Poverty |
$299,955 $1,044 12.2% |
|||
Source: 2015 ACS and 2021 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.
Based on the 2021 D&B data, GARs for businesses in the assessment area are:
84.5 percent have $1 million or less;
4.7 percent have more than $1 million; and,
10.8 percent have unknown revenues.
In 2021, the top industries in the Charleston MSA Assessment Area were services, followed by non-classified establishments, retail trade, and finance, insurance, and real estate. Top employers in the area include Medical University of SC Hospital Authority, Medical University of SC, The Boeing Company, Trident Medical Center, and Wal-Mart Associates Inc.
According to the Bureau of Labor Statistics, unemployment rates in the assessment area declined between 2018 and 2019, increased in 2020 due to the COVID Pandemic, and declined again during 2021. The following table reflects the unemployment rates and trends for the assessment area, State of South Carolina, and nation during the period.
Unemployment Rates - Charleston MSA Assessment Area
| Area | 2018 % | 2019 % | 2020 % | November 2021 % |
|---|---|---|---|---|
| Charleston County | 2.7 | 2.2 | 6.3 | 2.6 |
| South Carolina | 3.4 | 2.8 | 6.2 | 3.5 |
| National Average | 3.9 | 3.7 | 8.1 | 3.9 |
Source: Bureau of Labor Statistics
Competition
The Charleston MSA Assessment Area is significantly competitive in the financial services market.
The FDIC's June 30, 2021 Summary of Deposits revealed that 29 FDIC-insured institutions operated 122 offices within Charleston County. Of these institutions, Bank of the Lowcountry ranked 25th with a 0.2 percent deposit market share. The top five financial institutions accounted for 67.4 percent of the deposit market share and include Wells Fargo Bank, Bank of America, South State Bank, Truist Bank, and Pinnacle Bank.
Credit Needs
Considering demographic and economic data, examiners determined that small business loans represent a primary credit need of the assessment area. The significant percentage of businesses with gross annual revenues of $1 million or less and the large number of businesses with four or fewer employees support the conclusion that there is a need for small business lending. Affordable housing also represents a need, as 38.0 percent of the families are low- or moderate-income. In addition, the relatively high median gross rent of $1,044 within the assessment area support the need for affordable housing.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE CHARLESTON MSA ASSESSMENT AREA
LENDING TEST
Bank of the Lowcountry's lending performance within the Charleston MSA Assessment Area reflects satistactory performance. The bank's overall reasonable Geographic Distribution and Borrower Profile performance supports this conclusion. Lending in the Charleston MSA Assessment Area represents 18.5 percent by number and 25.8 percent by dollar volume of small business loans and 21.6 percent by number and 75.9 percent by dollar volume of home mortgage loans institution-wide.
Geographic Distribution
The bank's geographic distribution of loans reflects reasonable dispersion throughout the assessment area. Reasonable performance for small business lending supports this conclusion.
Small Business Loans
The geographic distribution of small business lending reflects reasonable dispersion throughout the assessment area. The bank did not originate any loans in low-income census tracts. However, given the level of competition within the low-income geographies (29 lenders with 122 offices), the bank's performance was considered reasonable. The bank's small business lending in moderate-income income census tracts exceeded demographics by 0.9 percent. The following table reflects the distribution of small business loans within the assessment area.
Geographic Distribution of Small Business Loans Assessment Area: Charleston MSA
| Tract Income Level | % of Businesses | # | % | $(000s) | % |
|---|---|---|---|---|---|
| Low | 11.5 | 0 | 0.0 | 0 | 0.0 |
| Moderate | 16.5 | 4 | 17.4 | 269 | 13.4 |
| Middle | 25.6 | 12 | 52.2 | 1,397 | 69.6 |
| Upper | 44.1 | 7 | 30.4 | 341 | 17.0 |
| Not Available | 2.3 | 0 | 0.0 | 0 | 0.0 |
| Totals | 100.0 | 23 | 100.0 | 2,007 | 100.0 |
Source: 2021 D&B Data; Bank Data
Home Mortgage Loans
The bank originated eight home mortgage loans within this assessment totaling approximately $7.8 million. Of these loans, one loan was extended within a low-income census tract and two were extended within moderate-income census tracts. Meaningful conclusions could not be formed given the limited number of home mortgage loans originated within this assessment area.
Borrower Profile
The overall distribution of borrowers reflects reasonable penetration among businesses of different sizes and borrower of different income levels. Reasonable lending performance for small business loans supports this conclusion.
Small Business Loans
The distribution of small business loans reflects reasonable penetration amount businesses of different sizes within the Charleston MSA Assessment Area. As reflected in the following table, the bank's lending to small business was 75.8 percent below demographics. However, it is important to note that 17 of the loans, or 73.9 percent, are PPP loans where revenues were not available for analysis purposes.
Including only loans with available revenue information, lending to small businesses was 33.3 percent, which remains significantly below demographics. While the bank is not required to collect and report small business loans, examiners noted that aggregate data for 2020 reflected that 38.5 percent of lenders originated loans to businesses with GAR of $1 million or less. The following table reflects the distribution of small business loans among businesses of different sizes.
Distribution of Small Business Loans by Gross Annual Revenue Category Assessment Area: Charleston MSA
| Gross Revenue Level | % of Businesses | # | % | $(000s) | % |
|---|---|---|---|---|---|
| <=$1,000,000 | 84.5 | 2 | 8.7 | 206 | 10.3 |
| >$1,000,000 | 4.7 | 3 | 13.0 | 923 | 46.0 |
| Revenue Not Available | 10.8 | 18 | 78.3 | 878 | 43.7 |
| Total | 100.0 | 23 | 100.0 | 2,007 | 100.0 |
Source: 2021 D&B Data, Bank Data.
Examiners also evaluated the PPP loans using loan size as a proxy for the size of the business served. A majority of the PPP loans originated in the assessment area, by number, had loan sizes of $100,000 or less, and all PPP loans had loan sizes of $250,000 or less, indicating that the bank is helping to serve the needs of small businesses in the assessment area. The following table reflects the distribution of PPP loans by loan size.
Distribution of PPP Loans by Loan Size Assessment Area: Charleston MSA
| Loan Size | Count | Percent | Dollars (000s) | Percent |
|---|---|---|---|---|
| <$100,000 | 13 | 76.5 | 290 | 33.4 |
| $100,000 - $249,999 | 4 | 23.5 | 579 | 66.6 |
| Total | 17 | 100.0 | 869 | 100.0 |
Source: 2021 D&B Data, Bank Data.
Home Mortgage Loans
Home Mortgage loan data reflects the bank originated eight loans totaling approximately $7.8 million within this assessment area. Of these loans, one loan totaling $120,000 was extended to a low-income borrower, and one loan totaling $199,000 was extended to a moderate-income borrower. Further, four loans totaling approximately $3.6 million were extended to borrowers with income not available. Due to the limited number of loans originated within this assessment area, meaningful conclusions could not be formed.
HILTON HEAD ISLAND MSA - Limited-Scope Review
DESCRIPTION OF INSTITUTION'S OPERATIONS IN THE HILTON HEAD ISLAND MSA ASSESSMENT AREA
The Hilton Head Island MSA Assessment Area consists of Jasper County in its entirety. The bank operates one, or 20.0 percent, of its branch offices in the Hilton Head Island MSA Assessment Area. The assessment area accounts for 2.1 percent of total loans by dollar amount and 16.4 percent of deposits institution-wide.
The Hilton Head Island MSA Assessment Area is comprised of five census tracts, including four moderate- and one NA- income census tract. Given the changes that resulted from the 2015 ACS, this assessment area's geography classifications changed from the previous evaluation where there were three moderate- and one middle-income census tract. The branch office in the area is located in a moderate-income census tract. The below table presents demographic information from the 2015 ACS census and 2021 D&B data.
Demographic Information of the Assessment Area Assessment Area: Hilton Head Island MSA
| Demographic Characteristics | # | Low % of # | Moderate % of # | Middle % of # | Upper % of # | NA* % of # |
|---|---|---|---|---|---|---|
| Geographies (Census Tracts) | 5 | 0.0 | 80.0 | 0.0 | 0.0 | 20.0 |
| Population by Geography | 26,549 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Housing Units by Geography | 10,729 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Owner-Occupied Units by Geography | 6,431 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Occupied Rental Units by Geography | 2,664 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Vacant Units by Geography | 1,634 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Businesses by Geography | 2,077 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Farms by Geography | 90 | 0.0 | 100.0 | 0.0 | 0.0 | 0.0 |
| Family Distribution by Income Level | 6,235 | 37.2 | 29.1 | 11.4 | 22.2 | 0.0 |
| Household Distribution by Income Level | 9,095 | 34.5 | 24.7 | 17.9 | 22.9 | 0.0 |
| Median Family Income MSA - 25940 Hilton Head Island-Bluffton, SC MSA | $63,345 | Median Housing Value Median Gross Rent Families Below Poverty |
$117,889 $801 17.2% |
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Source: 2015 ACS and 2021 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.
The Hilton Head Island MSA Assessment Area is moderately competitive in the financial services market. The FDIC's June 30, 2021 Summary of Deposits revealed that three FDIC-insured institutions operated four offices within this assessment area. Of these institutions, Bank of the Lowcountry ranked 2nd, with a 14.9 percent deposit market share. The top financial institution, South State Bank, accounted for 74.8 percent of the deposit market share.
CONCLUSIONS ON PERFORMANCE CRITERIA IN THE HILTON HEAD ISLAND MSA ASSESSMENT AREA
LENDING TEST
Bank of the Lowcountry's lending performance in the Hilton Head Island MSA Assessment Area is consistent with the institution's lending performance overall.
Geographic Distribution
Small business loan data reflects, the bank originated three loans totaling $106,000 within the Hilton Head Island MSA Assessment Area. All loans were extended within moderate-income geographies. Home mortgage data reflects the bank extended three loans totaling $283,000 within this assessment area. Similarly, all three loans were extended within moderate-income geographies.
Borrower Profile
Small business loan data reflects the bank originated three loans totaling $106,000. Of these small business loans, two were extended to small businesses with GARs of $1 million or less. The remaining loan was a PPP loan with no revenue data available. Home mortgage loan data reflects that the bank originated three loans totaling $283,000. Of these home mortgage loans, one was extended to a low-income borrower and one was extended to a borrower without available income.
APPENDICES
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, ommunity development loans, or qualified investments;
The percentage of loans, and as appropriate, other lending-related activities located in the bank's assessment areas;
The institution'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;
The geographic distribution of the bank's loans; 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 areas).
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.
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 , business or have banking offices in a metropolitan statistical area to file annual summary repor f their mortgage lending activity. The reports include such data as the race, gender, and th 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 MDA 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.