I am seeking to understand other bank's practices for governance for CRA programs. Specifically, is it common for a bank to have an articulated statement of its strategy (planned/preferred approach) to meet community lending needs and to provide CRA services to the community? (Note: not asking about a CRA strategic plan which the bank would be evaluated under.)

If so, what are some of the items management desires to memorialize, and what is the size of your bank? Thanks for the feedback, our bank is taking a fresh look at it's CRA management and we're approximately $3B in size.

Years ago, there used to be a requirement for banks to have a formal CRA statement. I believe that requirement went away sometime in the 90's, but I have seen some community banks still utilize a statement, though most haven't been updated since the 90's and were really just left in the public file because the bank didn't realize it was no longer required. I think a clear statement/plan could be beneficial for certain banks depending on size and other factors (like locations), but most banks under 1 billion in assets that I have worked with don't have a true articulated statement of strategy. Too often, community banks are more reactive with CRA than pro-active.