I'm updating our CRA Policy and have a question about this line; "The Board will review, at least annually, our CRA Statement and formally adopt it as required by regulation." I have not been able to find this in the regulation. Is this something that used to be required or was the person who wrote this adding unnecessary requirements?
Thanks for the help.

What size is your institution? I believe that is only for small banks and ISB's.

We are still a small bank, $265 million. Do you know where I can find that requirement? Thanks

I don't belive it is a formal requirement for the board to review the policy and "statement" I think this is a carry over from the old reg.

That being said, it is a good idea for the board to review and approve the policy so they are aware of what the bank is doing and what their and managements' responsibilities are.

Actually, there's no regulatory requirement to have either a CRA Policy or statement. At least that's what FDIC told me, so we elected not to have one. Just went through my Compliance Exam and everything was good.

It is a carry over from the old reg. No such requirement although it makes sense to document your "program"...what you are trying to accomplish in each category, how you will carry out your intentions, who needs to approve what, who does what, etc. Just like any other process.