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#131881 - 11/18/03 10:56 PM CRA Policy
Anonymous
Unregistered

Are we required to get a board approval every year for the CRA policy/statement? Or, do you advise board of any changes to the AA delineation?? Thank you.

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#131882 - 11/18/03 11:02 PM Re: CRA Policy
Andy_Z Online
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Andy_Z
Joined: Oct 2000
Posts: 27,769
On the Net
First, there isn't a requirement that you have a CRA policy. Second, if you have one I would recommend having all of them updated at least annually.

This has been discussed before. You can advise them of the changes only, but their reaffirmation of all polices, changed or not, a) forced a review of them to keep them up to date and b) demonstrates that the board's direction for those areas still stands.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
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#131883 - 11/19/03 01:33 AM Re: CRA Policy
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Ditto to Andy's comment. I update mine annually and point out any changes to the board. Obviously this year will cover changes in the AA, which I will have board approved.

While it's not mandatory, you're probably NUTS to not appraise the board of the bank's AA and the decisions to change the AA. A search for AA changes will probably get you to many discussions on the subject, but basically, you pick the AA, don't get managements buy off, then have a bad exam due to your concentration numbers....your head rolls.

On your policy, if you haven't updated it lately (ie in regards to Sunshine provisions) it's time to make the effort or the policy is really of no use at all.
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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