Answer:
by Rebekah Leonard:
Welcome to the world of CRA! It is a wondrous place, where detailed compliance meets the goodness of community outreach. smile
Here is my (subjective) to-do list:
1. Recognize this fact: as much as the regulators try to make CRA objective, there will always be a subjective nature to it. What works for one institution (and even what may have received CRA credit in your own institution at a prior exam) may not hold true for you at your next exam. Simply put: Past performance is no guarantee of future results. Keep this fact in mind, always.
See, that step was easy! smile
2. Recognize this next fact: Because CRA will always have some subjectivity, fight for what you really believe qualifies for CRA credit. It is OK to push back on examiners when you feel strongly about something.
I may have this step out of order, but it is a crucial principal to always keep in mind too. And it is another easy step. Look at you go! smile
3. Get the lay of the land, macro view: Learn everything you can about the CRA in general.
a. I suggest you start with (brace yourself) Wikipedia. shocked Getting a broad overview of why Congress created it will help you understand how you are going to carry out the spirit and intent of it in your bank.
b. Next, move on to the FRB's CRA webpage, here: https://www.federalreserve.gov/consumerscommunities/cra_about.htm This step will take you a bit, but do take the time to check out all the links provided on the left of that page. Your reading persistence will be rewarded.
Note: Skip the Proposed Rulemaking part for now. The CRA sands are going to shift (probably profoundly), but right now, you just need to learn the current state of affairs.
4. Get the lay of the land, micro view: What is your bank's CRA position?
a. Are you a large, intermediate small, or small bank?
b. Has management adopted a CRA Strategic plan?
c. Any wholesale or limited purpose designations? (Probably not, but these are game changers.)
b. What CRA rating does bank management desire? Do they want to achieve an Outstanding, or is "Satisfactory" just fine?
5. Armed with all your new knowledge, both of the big picture and your bank's specific position, read the CRA Exam procedures of your regulator. If you don't know where to find them, Google is a great tool -- just search for your regulator (like FDIC) and CRA Exam manual.
5. By now, you should have a good idea of what you need to do. Start keeping records of your community reinvestment loans, investments (donations too) and services.
6. Recognize this next fact: You'll never stop learning about Community Reinvestment. You'll get better at it, but you'll always be attending webinars, trainings, and working groups to learn from peers. To this end: ask your state banking association if they have a CRA peer group. If they do, join it!!
7. Check out BOL for CRA webinars and trainings and take them.
8. Check out https://cratoday.com/ I have no affiliation with this company, but Linda knows her stuff and her material is trustworthy.
9. Also check out GeoDataVision. Top notch, and a BOL supporter! https://geodatavision.com/cra-program-template-2/
Answer:
by Richard Insley:
CRA Officer - Now that you've read Rebekah's excellent advice, you may be looking at Toto and wondering when you left Kansas! If so, then congratulations...you've taken the most important first step in managing CRA so it doesn't bite you! The most successful institutions do not view CRA as a regulation, but rather as a way of life.
Maybe a "blast from the past" will keep you moving in the right direction.
One day, circa 1993, I opened the latest mail from our regulator (Fed) and found a rather innocuous one page notice...that soon resulted in seismic changes within our growing regional bank.
At the time, I was the company's compliance/CRA/etc/etc officer...if it dealt with a regulation, it was mine. I read it twice, and marched directly into my boss' office (senior in-house counsel for our BHC) and demanded that she read it...while I waited. She read it, and immediately called our CEO (her boss.) Within the hour, we were seated in his office...with my boss telling him the same thing I had told her. After reading it, he looked at me and said "you are no longer the bank's CRA officer." His next words were stunning -- "I am now the bank's CRA officer."
The announcement? It wasn't about a proposed or final rulemaking. It simply said that the banking regulators would henceforth expect banks to manage their CRA performance as seriously as they would manage a new product or business line and that agency examiners would evaluate and rate that performance. The hammer, of course, was that the agencies would consider a bank's CRA rating as part of the approval process for acquisitions, mergers, new offices, etc. What we all understood was that survival meant growth of our franchise...and it could be a "death penalty" to be held back.
For several months, our CEO did, in fact, chair a task force to reconfigure our CRA management, from top to bottom. With the changes in place, he handed the title of "CRA Officer" to our SVP in charge of marketing and directed him to manage it like a major new product line. We succeeded...while others were still trying to manage CRA like a regulation.
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