I recently joined a bank that had a dedicated CRA officer. This individual was very involved in several local non-profits and the bank benefited from the CRA credit. This individual is no longer with the bank and now our CRA service hours have fallen dramatically because other employees are not actively engaged in organizations that would qualify for CRA credit.

I need to decide whether or not we need another CRA officer. Currently, I am the Compliance Manager and also holding the title of CRA Officer. We have nearly 20 branches that cover a wide area. I will be advocating for our branch employees to become involved with qualifying organizations as we were criticized during our last exam for "having all our eggs in one basket" so to speak.

In my past, I was the CRA Officer for a bank with 36 branches. I organized and reported on our CRA activities; however, I was not personally involved in any organizations as I was also the compliance manager and really didn't have time to spend out of the office. We didn't have any issues during our CRA exams, as we had many employees participating.

I am interested in hearing from larger banks as to how you are managing CRA activities. If you have a dedicated CRA Officer, what is their role and responsibilities? Are they merely finding and coordinating activities or are they actively engaged with organizations or doing both? I'm just looking for ideas so that I can make a decision about staffing for my department.

I will share our CRA structure. We are an ISB but have 82 branches nationwide. I am a compliance analyst but my primary responsibility is tracking CRA activities. We also have a CRA officer (my boss) who supervises me and handles more of the investment side of CRA.

In OK we utilize our senior management staff to sit on boards etc. We rely on our regional and branch managers to perform the majority of our CRA services outside of OK. Our outlying branch managers sit on boards or teach financial literacy classes at various schools and community service organizations.

For a long time we only did CRA services in OK. Now we try to spread our activities out so we don't get criticized for the same thing. Sure we're more active in our home but all of our AA's had at least some service hours.

I think a lot of times banks do not utilize branch employees enough. I've found some employees that are super passionate about CRA and love going out and helping their communities. Hope that helps!

If you can get support from the top down, most of your services should come from the lines of business within your bank. It will be difficult to rely on branch staff alone. The majority are hourly in most banks, and they will not be allowed to rack up overtime doing community development services.

Many large banks require managers and loan officers to be involved in one or more community service organizations and well as being members of one or more chamber type organizations. This group should be your resource pool.

Staff in CRA/community development and compliance should only be the icing on the cake so to speak.

Thank you for your responses and I agree with both of you. Branch officers and staff are the face of the bank and should be out representing us with the organizations in our communities.

I'm feeling some pressure here to become involved with organizations, but I simply don't have the time (right now anyway).

Agree completely about CRA staff being the last resort. There's been some discussion about putting me on the board when one of the sr. managers retires next year. Unless things change drastically, I do not have time. I can think of a whole host of management with plenty of time on their hands.

For sure using branch staff requires striking a balance that works for CRA as well as the bank. Thus far, we've been pretty successful but I stay on top of the ones that are prone to spending too much time out of the branch.