I have just taken over CRA and have been asked to come up with a plan for the Bank. We are a wholesale bank and the definition of what is required by regulators seems much the same as any other bank. My CEO wants me to find out the minimum requirements for a wholesale bank but I can find no specific or definitive requirements anywhere. The regulation states loans based on no. and amount(same as retail bank), qualified investments etc. Are there specific minimum requirements? Are there any other wholesale banks out there??

The requirements for a wholesale bank are different in many ways from retail banks. Your performance is primarily assessed based on community development activities. There are 228 performance evaluations for 149 different wholesale lenders listed in the Performance Evaluation database as of June 27. I would suggest that you download and read a few of those PE's to get an idea of what is expected. Everything is performance context driven in CRA. So you should develop a community needs assessment that will establish the primary reference points for evaluating your performance.

Thanks so much for your help.