How is CRA organized at your institution?
What Asset size are you?
What title does the CRA officer carry - AVP, VP, SVP,etc.?
Who does the CRA officer report to - senior management, the board?
Does the CRA officer have staff?
If so, how many and what are their functions?
What does your CRA officer do - investigate loan products, investments, write the program, do the reports, ....?

I appreciate your time with this little questionnaire.

How is CRA organized at your institution?
Organized is such an ugly word What do you mean? Are you asking where reporting takes place, or what division we report to?

What Asset size are you?
Just over $2 Billion

What title does the CRA officer carry - AVP, VP, SVP,etc.?
Prior to me, "CRA Officer" With the addition of "Dawnie" the title currently is VP. The title is given based on merit and skill so if I left, while I've sent a precident that they could get to VP, I would imagine they'd start at the "CRA Officer or AVP level at the highest" (heads turned when they made me VP...lenders were scandalized)

Who does the CRA officer report to - senior management, the board?
I report to the King of Compliance SVP and Chief Council. I do not report to all senior management as a committee (gad would that be a nightmare or what!) I also meet with the CRA Committee (Board of Directors) but do not directly report to them.

Does the CRA officer have staff?
Yes, thank god!

If so, how many and what are their functions?
2 direct reports both full time.
1 is titled "Community Relations Assistant" and is generally an admin position, processing paperwork for the unit, gathering donation requests, doing research, and PRIMARILY geocoding LAR and LR entries as well as submitting those reports.
The second is a CRA Specialist. She is a higher position, more distinctly trained in technical work in the department. It is an exempt position. She does training for branches locally, works closely with clients, writes and manages grants through FHLB, manages teh computer or "techie" stuff in the department, organizes functions, all data integrity, CD writeups on multifamily loans, all services and all donations,...gad when I think of this I realize she needs another raise
And then there's me.

What does your CRA officer do - investigate loan products, investments, write the program, do the reports, ....? All of that and more. I develop lending relationships, manage certain loan products, manage the CDE partnership, romance tax credit opportunities and develop them years in advance of actual tax credit deals coming into the office for approval (ie I work closely on New Market and Wind Energy investments prior to inception) ummm lets see, manage the bank's donation committee and CRA donation funds, appraise the board of the status of "CRA" as time goes by, represent the bank at social and business functions, seek deposit opportunities, review or develop expansion opportunities (new branches) umm what else is on my desk right now? My speaking engagements are written into the job (maintain national expertise level in CRA) I Fish with clients, attend any wine tastings necessary buy dinner for oil companies etc. I often describe myself as "Bank Cheerleader" with a brain If anything else crosses my desk today, I'll add it LOL

Dawnie is most definitely the Queen!!! We try to guage our program against hers to see where we're at between exams!

What Asset size are you?
We're closing in on 1.7 B

What title does the CRA officer carry - AVP, VP, SVP,etc.?
CRA Officer - the first officer level, but like Dawnie - it's a merit thing. As the person performs well, they move up!

Who does the CRA officer report to - senior management, the board?
To the SVP Compliance Manager

Does the CRA officer have staff? If so, how many and what are their functions?
No direct reports, but two high-time data specialists (collect HMDA and CRA data)work mostly with CRA and access to a couple of other people for help with special projects.

What does your CRA officer do - investigate loan products, investments, write the program, do the reports, ....?

All of that, plus analyze data, ensure accurate timely HMDA and CRA reporting, coordinate with staff in different markets, look for investment opportunities, service opportunities, try to identify CD loans, etc., etc.

Heh heh, Lestie I always forget that I identify CD loans too and do the staff coordinating, blah blah

I also suck up to examiners. (Matt are you out there? You sure look good today!!!)

And thanks for the compliment Lestie We were just notified we can share our latest rating....OUTSTANDING AGAIN!!!! Golden girl for three more years LOL

How timely. My Boss just gave me the directive to investigate how other banks our size or near our size are structured for CRA. We are at $3 Billion.

There are two of us in the department. We do all the CRA and HMDA reporting. My job resembles Dawnies but I don't have that middle person doing those things. Guess that is why they don't get done.

I am supposed to restructure my job to spend less time out in the public and more in the bank doing reporting and finding opportunities for the bank. I personally think that is better accomplished out meeting with the public and finding opportunities. HELP Dawnie, I need some guidance here.

Thanks to all for your responses. I really appreciate it.

Geeze KC what are they thinking? Do lenders find more loans sitting on their behinds in the office, or by pounding the pavement? Deals don't walk in the door for me. I find them by being out in the community. We actually hired that third person because I was having trouble getting "out"! My job description says 60% AWAY from the office, not 60% in the office.

Here's some fuel for your fires: My most recent deals hunted while outside of the office:

Last week on vacation: $2.5MM purchase of a waterfront property which is currently occupied by a defunct cannary. In addition to that deal (in the works the day I returned), a refi of a commercial property for $500M and I'm meeting with a large entity to discuss moving $25MM to the bank which would be enough for me to consider a new branch location in their region. All of this while on a fishing trip. I made a $1M donation to the fireworks show during the 4th of July parade and all three deals followed me to the picnic to talk turkey and set up appointments this week. (I also caught 3 king salmons) These deals (aside from the salmon ) will NOT be CRA deals, but will be strong credit deals for the bank. I have one other client I'm meeting in a similar community to discuss bringing in $35MM if I would consider opening a branch (and for that amount I would)

Summer: From a golf boondoggle in Arizona (sure it was a bank trip) $10MM to $15MM deal in the works to partner on a tax credit (energy) purchase which will be CRA qualified (and probably the first CRA qualified on in the nation)

Over a glass of wine at the club: Two $5MM tax credit partnerships, again for energy, serving rural AK. This is a client I brought into the bank early in the year, annual revenues around $100MM, lock box services and a $3MM line of credit. A couple years ago over another glass of wine (you sense a theme huh?) I brought in one of their LLC's to the tune of around $1MM.

Let's see....oh at a picnic for an oil company, Two refi'd jumbo home loans to oil execs (both in excess of $600M have closed) and one for their assistant which closed last week at $260M.

At a wine auction: $2MM senior housing construction loan. This will be a CRA CD loan for the next exam.

Dinner with a good client: $5MM Loan to be used for operations of their CDE. Parent company stronger than God This will be a slam dunk CRA CD loan.

I have about $15MM in rural housing deals in the works, all garnered while in the individual communities they are operating in. Most of these were initiated while I was at a local housing seminar.

Oh lets see, then there was dinner in Oregon after a seminar. Suprisingly enough the speaker was "so/so" and had no actual experience putting together the product he was speaking about. On the other hand, we lead the nation in the number of these deals book so he referred to me quite often with questions. Unbeknownst to me, a prospect we haven't been able to get our foot in the door with was sitting in the audience. The attacked me while I was enjoying a steak (yes with a bottle of great wine) at the restaurant and are now booking their third deal with us and working on a $10MM LIHTC deal which we put in front of our syndicator so we could get first dibs on.

Is that enough fuel? Oh wait, there's the board I sit on for a non-profit who just opened their line of credit, $1MM as well as a couple equipment loans

You can see that if I sat in the office I wouldn't have picked up any of these can't you? None of these folks called me in the office. They saw me while I was out in their communities or, in the case of the club, they know that I "am" my bank and they come forward carrying a glass of wine and questions My predecessor sat in the office all day. She, on average, took in a few phone calls with crap deals which didn't materialize. I was hired to be "out" because the bank saw opportunity in having an experienced lender hob nobbing and glad handing out in the community They also kind of wanted to get an Outstanding rating, which we have maintained, even with me "out" of the office the majority of the time.

So KC, up your schmooze budget and get your arse out of the office!!!

We are a bank holding company and are looking into creating a "regional CRA officer" position. Currently at the corporate level we have someone who is responsible for the HMDA/CRA government report filing and the compliance officers at each bank do their own data integrity review and each bank has their own CRA officer. However the organization is looking at efficiences and wondered if it would be possible to do this "regionally" verus each bank continuing to have their own person. Would appreciate any thoughts on this (pros/cons) and/or if any one is already doing something like it... Thank you.

yes, you will be much more efficient that way and possibly control your error rate better by regionalizing. Ours has been that way for quite some time with just a "CRA contact" out at the outlying offices.

Brody, there are many banks who have somewhat similar positions. My question to you would be...what's a region? We currently see one large bank here in Alaska who has let their CRA officer go and they never bothered to replace her. The bank uses a "regional" officer out of Washington, who's rarely, if ever in the state. If that's "regional" I don't recommend it. Community groups are starting to comment in a less than favorable way about this bank. In addition, if you scroll up to my post on leads I develop in the community, you can see that a regional person wouldn't have as much luck with that type of success, not being in the actual communities full time.

Wells has a regional CRA position as well, but they locate one CRA officer (a hand shaker and check hander outter) in each state. Still, despite the lower responsability level, they look good in the eyes of the examiners and the community groups because of the local position.

Were it me, I'd suggest you regionalize the data portion of the job first, and then look to the CRA officer. Keeping that front line person on board and out in the communities has value, but there's no need to do data integrity in each location. If your CRA folks aren't out finding deals, look to new CRA folks. There is no reason CRA shouldn't be a profit center, verses a loss leader. If you're only seeing money go out the door, they're not really doing their job right But...you have to give them time to do it of course Getting that data gathering and verifying goober off their desk would be a good start to seeing them pull in some real money for the bank.

Joker - what is the CRA contact responsible for? Do you have a corporate CRA Officer? Our main concern about "regionalizing" is just as Dawnie mentioned, is losing that contact within a specific community. A regional person would not know the entire market and specifics of the area. We are working on regionalizing our compliance function and for the most part CRA has been separate from that, but perhaps the regional COs could do the data integrity. We've always thought the CRA officer would be the main lender/senior lender in the bank since they generally would have the contacts. Perhaps that person could be the community contact?

As an ex lender....please don't force that person to be your CRA contact. I'll tell you that for a local bank, it hasn't worked (large bank in several states). The senior lender just does not have the time to be a CRA expert of any value. Let them do their jobs...LEND! (besides, most of us CRA folks are much cheeper than lenders)