Is anyone willing to share where the CRA Program resides within their institution? We are a large bank by CRA standards and there is some question on whether to restructure the CRA responsibilities and have both line 1 and line 2 CRA functions.

Currently our CRA Officer/Manager resides in a Line 1 space, but we are looking to see what other institutions are doing in relation to the day-to-day functions and the overarching program management.

Thanks for any opinions/thoughts shared.

Our community development lenders and community relationship staff are in the first line, but our CRA officer is in the second line.

InFairness - Thank you for your response. Does your institution fall within the CRA Large Bank classification?