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#764242 - 06/28/07 09:07 PM Board Approval of Expanded Assessment Area?
compliancegeek Offline
100 Club
Joined: Jul 2004
Posts: 129
Midwest
We opened a branch in a new market. I have read the CRA but don't see where we would be required to obtain Board approval of the new assessment area. Does anyone have any suggestions?

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#764324 - 06/28/07 10:13 PM Re: Board Approval of Expanded Assessment Area? compliancegeek
CRAatBOK Offline

Power Poster
Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
You don't have to have board approval but we notify the board of the new or expanded AA.
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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#764397 - 06/29/07 01:45 AM Re: Board Approval of Expanded Assessment Area? CRAatBOK
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,143
Connecticut
The Board ultimately is responsible for your compliance with any and all regulations, including CRA. Although CRA itself does not explicitly require Board approval of changes to the Assessment Area it certainly would be a poor reflection on the compliance process if such a critical decision were made without Board approval. The decision on how to delineate your assessment area may be your most important CRA decision because it affects every other aspect of your CRA performance. Furthermore, examiners not only assess your performance under CRA, they observe the "process" itself. If the Board does not have compliance controls in place that assure it is informed about important compliance decisions, it would seem to me to be a glaring omission. Finally, why wouldn't the Board be involved in such a decision? Don't forget that the Assessment Area is supposed to define your market. Aside from its compliance implications it is a strategic market decision that should involve the highest levels of authority within the bank.
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#764723 - 06/29/07 03:03 PM Re: Board Approval of Expanded Assessment Area? Len S
Carolyn31 Offline
100 Club
Joined: Nov 2005
Posts: 101
Nebraska
I have a board level CRA Committee. When we changed our assessment area last year the committee approved the change and was reflected in our minutes that also goes to the board for review.

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