CRA Examination Procedures Are Out

The good news is that they really are uniform, as written. In implementation, time will tell. However, keeping them uniform is partly the responsibility of banks. Every compliance manager should be thoroughly familiar with the examination procedures, including what is "in between the lines." Banks should closely manage CRA examinations, both to be certain that the examiner stays within the scheme of the procedures, and to learn from and with the examiner.

One additional note on CRA examinations. The procedures direct the examiner to compare information from and prior CRA evaluations of institutions of similar size that serve the same or a similar assessment area. You should be there a step ahead of the examiner. Part of knowing your market must include knowing what other banks are doing. This information can be used to compare your bank to other banks, and to justify or illustrate differences in business strategy.

Copyright © 1996 Compliance Action. Originally appeared in Compliance Action, Vol. 1, No. 3, 1/96