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#1504286 - 02/03/11 12:43 AM CRA Officer Appointment Needed??
Sisyphus Offline
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Sisyphus
Joined: Jun 2008
Posts: 222
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?

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#1504290 - 02/03/11 01:07 AM Re: CRA Officer Appointment Needed?? Sisyphus
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
It is not required and I have worked at and worked with many banks that do not have a named CRA officer. As long as all of the required elements are assigned and handled well, it is fine.

The process you describe is common. Just make sure that the person who is "monitoring" keeps an eye on requirements and performance.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1504312 - 02/03/11 02:21 AM Re: CRA Officer Appointment Needed?? Kathleen O. Blanchard
Sisyphus Offline
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Sisyphus
Joined: Jun 2008
Posts: 222
Thank you!

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#1518603 - 03/08/11 01:54 PM Re: CRA Officer Appointment Needed?? Sisyphus
BSARocksagain Offline
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BSARocksagain
Joined: May 2010
Posts: 67
Maryland
Does the CRA Officer need to be appointed by the Board?

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#1518616 - 03/08/11 02:21 PM Re: CRA Officer Appointment Needed?? BSARocksagain
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
There is no federal requirement that a bank have a CRA Officer. Any requirement to appoint one and have that officer appointed by the Board is a matter of bank policy.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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