Moving to large bank under CRA
by Andy Zavoina, BOL Guru
Question: When a bank goes from being a small bank to a large bank, what needs to be done differently as far as CRA is
involved?
Answer: This list would be very long. You have separate recordkeeping requirements, your public file changes and you must review your investments more closely, including donations.
The best advice I could give is to contact your regulator
and ask if they have a class they can present to your senior management group on this transition.
They will review what is changed and where emphasis is needed, based on your particular circumstances. This will assist in your bank’s understanding of the rules and help you with senior management “buy-in” for what will be needed in the future.
You should also thoroughly review your examiner’s exam questionnaires and self-audit your institution
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