Is 2015 the latest release for the A Guide to CRA Data Collection and Reporting? That's the most current version I am seeing on the FFIEC's Web site.

Based on last year's assets and what they will be at the end of this year we are going to move into the Intermediate Small Bank category and if I am reading FDIC 345.26(2)(c) correctly we are going to have to start tracking our CD loans. CRA is not something I have had to deal with in the past so I was looking at getting a copy of the CRA "GIR" to try to get a jump of what I need to be looking for. Just want to make sure the 2015 release is the current one.

Thanks.

Once you become an ISB you are immediately subject to ISB exam standards which means that CD activity goes from not even being a part of your performance requirements to being absolutely essential and it is effective immediately and retroactively.

Yes, you read that right. If you are subject to a CRA exam the month after you officially become an ISB you will be subject to ISB exam standards which make CD activity an absolute requirement to earn a composite "satisfactory" performance rating. So if you expect to become an ISB on January 1, 2022 you should immediately commence a community development program.

When I once asked a FDIC Field Review Supervisor about the fairness of this practice her response was the bank should have anticipated its transition to ISB status and the implications in terms of performance expectations.

I received a similar response from the head of Supervision and Regulation at a Federal Reserve Bank several years ago.

Thanks Len - we are already noting some loans and other activity that we think will qualify for CD credits and I'm scheduled to attend a Webinar on the 19th that will cover identifying and documenting CD activities.

I was hoping the ISB category wouldn't hit us until I retired. I'm not ready to retire for a at least a couple more years so looks like this old dog is going to have to learn a couple of new tricks.

Our last CRA exam was at the beginning of 2020 so at least I have a little time before our next CRA exam.

You should be good until 2023 - just before what I suspect will be the "new" CRA that will be proposed and approved in the next 8 or 9 months!!!

What are you anticipating to be the "new CRA"? I probably have glanced at emails and the like but just a summary?

I will be speaking at the 12th Annual M&M Regulatory Compliance School in September in Massachusetts and one of my topics is CRA "Modernization" - what to expect. And there will be big changes. Assessment Area rules will change, deposits are likely to become a data collection item. The concept of "comparators" will be implemented, Loan balances, not just loans originated or purchased may be brought in to measure the long-term effect of lending in the community. There is plenty to anticipate. For sure, when the NPR comes out, bankers had better be prepared. The politicians in control in DC have complained that the CRA exam failure rate is too low - what do you think that may lead to? Yes, the regulators read the election returns too!!

I don't expect a new CRA Guide until the Agencies get their act together and issue a new rule. I expect a CRA NPR sometime this Fall, followed by a 90-day comment period. Sometime next spring we are likely to see a new joint rule that will be effective in 2024. When that becomes effective is when I expect the new CRA Guide to be issued. In the meantime keep your eyes open for any new guidance. Last year the agencies issued several bulletins on CRA and Covid-19.