I've never heard of a bank that did not appoint someone as a CRA Officer, but does anyone know whether such an appointment is actually required for a non-member,state-chartered (FDIC) bank?
Does anyone see an issue if the Compliance Officer or Loan Operations Manager fulfills that role from a back-office perspective; e.g., technical requirements; reports lending data to the Chief Lending Officer; oversees CRA exams, and relies on the lenders to go out and lend?