What is the advantage to developing a CRA Strategic Plan as outlined under 228.27?

Strategic plans are useful for banks that are not traditional banks with bricks and mortar branches and without traditional consumer products. Wholesale, limited purpose, and internet banks are good candidates for strategic plans. A great deal of work goes into the development and approval of the plan but the bank then has definite goals to achieve.

Here is an interesting article from a bank with a strategic plan.

http://www.frbsf.org/publications/community/investments/cranews/8-3strat.html

Interesting. I think I'll stick with the self assessment.

Amen Mel in WA, we have a credit card bank with a SP, no fun!

In regards to strategic plans, the branch notice requirements indicate that "If we are operating under an approved strategic plan, you may also have access to a copy of the plan". Althoug its not a requirement, does anyone include a copy of this in their branch files? Or would you just give it upon request?

Banks operating under strategic plans must keep a copy in the public file:

(4) Banks with strategic plans. A bank that has been approved to be assessed under a strategic plan shall include in its public file a copy of that plan. A bank need not include information submitted to the Board on a confidential basis in conjunction with the plan.

So this strategic plan that the bank operated under, would this be of the noted banks listed on the FDIC website as having a strategic plan that the regulation notification requirement is referring to or is this a in house bank-wide strategic plan that the regulation is referring to?

This means an official legal strategic plan that the bank is operating under and is examined against, not just a plan you have internally to achieve your goals.