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#357000 - 05/07/05 01:31 PM Internet Banking and CRA
Anonymous
Unregistered

My bank is launching Internet banking next week. I'm the compliance officer and just heard about it today. I have a million concerns and your website is helping me with those. But, what about CRA. If we take applications from gosh knows where, how does that impact our CRA? All these people will be outside our AA. Is there a place on bankers on line I can go to for how to handle this? I haven't found that yet. Any help you can provide will be appreciated. Thank you.

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CRA
#357001 - 05/10/05 12:36 AM Re: Internet Banking and CRA
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
It isn't necessarily true that your figures within your AA will decline. You have only to wait and see, but let's cover the worst case scenario. They might. If they do, you will be challenged with a small portion of the lending test. If you're doing great otherwise, no biggie, it's a VERY small piece. If you're not doing well, this won't help.

So how are you doing otherwise, and where is "gosh knows where"? WOuld you take my application from Alaska? I probably wouldn't take yours, even though I do allow internet banking. This is a lending policy question you need to answer PRIOR to coming on line with this product. Take the full picture of CRA into account, and your safety and soundness as well. I'd focus on the second more than the first frankly.

Once you've answered that, look to your peers and see what their inside/outside ratios are. Try to stay above 50% and perhaps far above that if this is what the peers are at. (I'm near 95% because my peers are as well). If you are within your peers, don't worry about it. It's a very small part of the test.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#357002 - 05/10/05 01:06 PM Re: Internet Banking and CRA
Anonymous
Unregistered

Thank you for responding Dawnie. May I impose upon you for one more answer? Can I state on the website that applications for loans can only be accepted from people who live ________(and fill in the towns in which I'm willing to accept loans)_________? Should I also do that for deposits so that I don't get the Alaska deposit or loan application?

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#357003 - 05/11/05 01:28 AM Re: Internet Banking and CRA
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I would love to answer that...but that's a question above my pretty little head I think you should post that question in the lending threads so that you get an Andy or Dan or anyother brain response. I love to lead you to water...but at the point you lean down to drink I sometimes have to pull the bathplug

There might charter, state, and fed regs you have to worry about. I do know that my lending policy covers this, but frankly, I don't see it on the website. I guess I need to chat with the compliance buddies here in my office as well
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#357004 - 05/11/05 02:05 PM Re: Internet Banking and CRA
Anonymous
Unregistered

Thank you Dawnie. I'll go there no. I'm awful thirsty!

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#357005 - 05/11/05 08:01 PM Re: Internet Banking and CRA
KAT Offline
Platinum Poster
Joined: Aug 2004
Posts: 986
Massachusetts
I used to work for a bank that had lending in 7 states. All states have different requirements for being able to lend in them. If you are OCC you can lend anywhere. Other than that you might need a license. ME, MA, NH and RI you need a license. NY, if you do more than 5 loans you need a license.

What we did was get the web site set up so the customers would be redirected to another site after we told them we only lent in certain states.

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