What are the requirements, if any, in doing a formal annual CRA self analysis? If it isn't actually required, how many banks do it and to whom is it reported? The BOD or a committee of such?

Bettysea - I do it annually and report it to our Board, our CRA Committee (which includes a few Board members), our General Compliance Officer, and our Auditing officer. I also provide it to the FDIC with our pre-examination materials.

CubDave

Is it required?

No - I can't imagine it's required. I do it because it serves many purposes, most importnatly, it keeps me organized and allows me to update issues along the way and serves as a document to present to the board. I know an old example used to be in the BOL toolkit, although I have changed mine a bit to most importantly, include a cover page that bullet points any and all new significant items since the last exam, including new CRA Investment programs, etc.

There is no requirement for an annual assessment on your bank, but realisticly, if you don't do it, how do you know where you sit come exam time?

I do quarterly cumulative (cumulative through the exam period) reports which are shared with the Board of Directors (we take CRA seriously here) as well as a full Preformance Examination (yup just like the examiners do) on an annual basis.

When you have your eventual exam they do ask for your board reports or self assessments. Having nothing isn't going to penalize you, but if you put yourself in your examiners shoes, how would it look to you? If the bank isn't paying any attention to CRA during the period of the exam, how can they possibly put together a performance context of any value?

Another hint...I've seen MANY of my internal PE results repeated word for word in my actual PE from the examiner. When you provide them with a factual assessment, as well as the performance context in a document structured exactly the same as theirs, it's only human to cut and paste the stuff that makes sense into the final exam

Second hint, don't overrate yourself in your internal PE. Don't beat yourself up if you don't need it, but try to be objective. I've seen folks rate themselfs outstanding, outstanding, outstanding...when they actually should have been outstanding, low satisfactory, satisfactory. This type of internal exam is going to end up in the round file and won't establish any credibility with your examiner when the real exam comes around.

Being new to the CRA area, are there any software programs that will help with self analysis? I have seen CRA Whiz mentioned in some threads. Is this one program?

I'm sorry but PCI stands for......

Don't think it stands for anything - Their web site

PCI used to stand for something years ago but as they diversified it no longer was as relevant.

We do a modified self-analysis. Well let me put it another way. We operate under a CRA Strategic Plan, so in the process of writing the plan we do a major analysis. Then monthly we pull down our numbers and compare them to our goals and see if we are in compliance. It leaves almost all of the guess work our of the exam process.

Hi Twin1 I'm a twin 2 or too I guess

I use PCI and am quite happy with their programs but depending on your needs (size of the bank, structure) you should also consider other companies out there as well to find the best fit. I'm a $2.3 one state institution but for some smaller institutions the costs aren't always in line with your needs. There are some wonderful consulting companies who bear the burden of the computer and data costs for you, but provide you with the same types of information (folks like Don). It's best to figure out which is most cost effective for your firm before deciding on any one company.

Again, I love the Wiz, but I like the ability to pull up obscure data at the drop of a hat and don't have issues with the costs as I use the program to it's very fullest potential but when deciding to stay with the Wiz (I re-evaluate every few years just to keep in tune with the market) I did find some great options out there, but for me the fit continued to be PCI.