Old National Bank CRA Policy

It is the policy of Old National Bank to use its best efforts, within the scope of its resources and in a safe and sound manner, to meet the credit needs of its entire community and to provide banking services to its entire community.  Special effort and consideration shall be given to the needs of small businesses and small farms and to the needs of low- and moderate-income people particularly in regard to residential real estate credit.  Old National Bank is adopting this policy not only because of its obligation to serve its entire community, but also because this policy will make a stronger community and in turn a stronger, more profitable bank.

In furtherance of this policy, management of the bank shall maintain a dialogue with all elements of its community, particularly low- and moderate-income people, for the purpose of understanding their credit needs and creating products and delivery systems for those products to meet those needs.  Management shall appoint a community development manager who shall have the responsibility of monitoring the bank’s lending, investments, and services qualified for community development, and evaluating its performance under this policy.  The community development manager shall report to the Board of Directors at least annually on the results of the bank’s compliance with this policy.

The community development manager shall maintain the bank’s public file and notices in conformity with Regulation BB, the implementation regulation for the Community Reinvestment Act.  Old National Bank shall conduct educational programs for company employees regarding the bank’s policy and the requirements of the regulation.