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#582559 - 07/12/06 03:20 PM CRA Committee
baseball banker Offline
Junior Member
baseball banker
Joined: Jul 2005
Posts: 48
California
The Board of Directors recently reorganized the CRA committee and there are a number of new members. The committee is comprised of Board members and Bank Staff.
The question which has developed is, "What is the role of the CRA Committee?" Currently the committee reviews some of the required reports, but really doesnt seem to have much of a role beyond that. The new members from the Board of Directors are questioning if they should be "doing more".
What do some other Banks have the CRA Committee oversee?

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#582560 - 07/13/06 05:35 AM Re: CRA Committee
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Well if your reports indicate that you guys are doing a phenomenal job in all aspects of CRA, then there won't be very much for the Committee to do other than say "Well done."

If your reports indicate that there are areas where you are marginal, or perhaps a bit lackluster, then the job of the Committee is to focus on how to IMPROVE the performance.

What risk is the bank willing to take in order to improve their CRA performance? Will it invest in an innovative product that carries a higher investment risk or lower rate of return? Will it consider alternative lending practices to enhance affordable housing to low/mod income residents that may carry a higher credit risk, lower rate of return, or require additional monitoring burdens? Will the bank require additional participation by officers to provide Community Development Services?

If your Committee is just sitting there accepting reports and not acting on them, then either your Committee members don't understand their role, or you need different people on the Committee.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#582561 - 07/13/06 12:50 PM Re: CRA Committee
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Additionally, some committees approve grants (some only do over a certain $ amount) and investments.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#582562 - 07/13/06 03:43 PM Re: CRA Committee
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,146
Connecticut
Ideally the Committee should have some performance goals that it should be comparing your performance to. For example, "What is the benchmark for lending in LMI areas and how does our performance compare?" When performance deviates from target the Committee should determine the reason and help to develop a plan of action. The meeting minutes should be documented and a book maintained.
Second, the Committee should be evaluating and monitoring your "process", i.e., the systems and procedures to assure the integrity of your data in the first place. There should be an annual review done by the CRA Officer and presented to the Committee certifying the written procedures are up-to-date and complete and consistent with the regulations. If there have been changes put into effect the changes should be documented and explained to the Committee. There should be a periodic presentation by your auditor (or third party) of any review of CRA performance and/or processes. Finally, there should be an annual report to the Committee regarding the training of personnel in order to confirm that all responsible personnel are informed and up-to-date on the regulation and the latest revisions, Q & A's, FIL's, Bulletins, etc.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#582563 - 07/13/06 03:49 PM Re: CRA Committee
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,146
Connecticut
I should have added one more consideration. CRA meetings can be much more than a boring and confusing recitation of statistics. Every member of the CRA Committee should understand that CRA boils down to "meeting the need for credit services in the community". This is marketing 101 and CRA can be made much more interesting, informative, provocative and profitable when approached from this point of view. The Committee really should have a good idea of the credit markets in your areas, the competitive structure of the loan markets, the size and geographic distribution of those markets and how your bank ranks and compares to other lenders active in your market. This means you should have market rank and market share reports of your HMDA and Small Business and Small Farm Loan markets. Having these kinds of reports can stimulate thinking and debate about the kind of job your bank is doing providing loan services and how it can be improved. This translates not only into better CRA compliance performance. It can also make the bank more profitable.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#582564 - 07/13/06 04:06 PM Re: CRA Committee
Bullseye Offline
Platinum Poster
Bullseye
Joined: Jan 2004
Posts: 968
Our committee is similar to what Len described. We review our totals in each area examined and compare them to the PE's of other banks our size and in our area. We look for gaps and then try to generate ideas for filling the gaps, such as targeted marketing if we need to grow in a certain area. We also look at things such as recognizing staff that provide CD Services to encourage them to keep up the good work & encourage other staff to participate. The group also reviews our policy annually for presenatation to the board.

BTW, we are an ISB and we update our numbers and meet on a quarterly basis.
Last edited by Drowning; 07/13/06 04:07 PM.
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