Can anyone provide me with suggestions for collecting community development loan data? Now that we are not reporting any CRA data, the process for collect community development data has disappeared and the lenders don't want to spend time notifying the compliance group of potential CD loans.

Any ideas would be appreciated.

That should not be the lenders choice. The bank needs the info. Why can't the prior process be re-instituted?

Many banks have compliance do file reviews anyway, for data integrity (when they are a reporter) and to identify CD loans lenders might miss. I don't like to rely solely on lenders unless the bank has a really really good process.

You could get reports of new loans booked and select those you want to review, or obtain copies of new loan writeups.

I agree with your comments. I'm just wondering if there are any existing methods that would allow us to identify these loans with limited or no lender involvement. I haven't been able to think of anything.

Just doing loan file reviews yourself, as I stated - get reports of new loans, get copies of new loan writeups, and select those you want to review (or review all).

Susan, I'm the in the same boat. I don't have time to review new files in hopes of finding potential Comm Dev. loans. And management shot odwn my idea of implementing a Comm. Dev. reporting process for loans and services. They don't want to place any extra work on the branches.

I am now trying to work with our loan doc. reviewers to see if they can flag potential Comm. Dev. loans for me to review. Still going to be a pain because only the loan officer is giong to know all the true details on the loan.

Maybe my reporting procees will be resurrected after our next CRA exam.

If you have dropped data collection and review completely you will have a problem. At the FRB Community Development Conference a couple weeks ago the OCC, FDIC and FRB representatives stated.

"We won't say a bank should or should not collect and review their data, BUT we expect them to "Know their story, and be able to tell it"

Some bankers then indicated that in ISB exams held in the past month they were severly critized for not haveing data and people in the bank not being able to answer their questons.

It was CLEARLY stated the the term No Data Collection means you don't have to collect data for REPORTING PURPOSES. It does not mean you should not collect and review it at all.

In two instances examiners resorted to the Sampleing methodology and both banks were told they were less than satisfactory based on the examiners sample. The bank felt ther was no problem but could not defend itself because they had no data.

Is there any way you can get copies of new loan writeups so that you can quickly review them for anything that smacks of CRA? You can then do a more in depth review of those that look likely.

Our loan documentation is centralized and part of their process is to make a "packet" with items such as the loan officers credit request (which states the prudent information about the loan)and these packets are kept in our Loan Operations Dept. It helps to do it this way because 9 times out of 10 I can make a decision about a loan qualifying for CRA without ever contacting the loan officer or having the complete loan file.

I attended the same conference that Don mentioned and one suggestion that I think is a great idea is for the CRA Officer (or the person responsible for CRA) to sit on the Loan Committee. That way you will hear the discussions about the loans without having to review ALL loan files. (I'm in the same boat - without additional staffing I just don't have time to review EVERY loan file.) If you can't get put on the Loan Committee, at least get access to the minutes. This should help.

The revised CRA has significant implications for community development activities thereby making any forms previously used outdated. In particular, the addition of the 3 new census tract categories is a major novelty subject to change at any time (disaster tracts). Moreover, what constitutes community development activity in distressed tracts is different from what qualifies as community development in underserved tracts. Also, I have found that many banks are totally unaware of "areas targeted by local, state or tribal government" that may qualify loans as community development. Keep in mind that, with some very rare exceptions, most notably multi-family affordable housing, community development loans are the loans that are not reported as small business or small farm or HMDA mortgages. So the places you would look would be the larger loans and the non-reported loans.
I believe community development issues have become much more complicated by the revised regulation (a major goal of which was to provide "regulatory relief"). Even banks with well-established community development programs are going to have to revisit how they operate and track these activities.