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#385690 - 07/13/05 10:04 PM CRA Exam
Texas Boy Offline
Diamond Poster
Joined: May 2005
Posts: 1,717
We are a bank with >$250 million in assets with a satisfactory rating. I received a letter in the mail on Monday July 11 from the Fed requesting some information needed to complete an off-site monitoring program. Since our last compliance examination, we have doubled in size and have gone through numerous personnel changes. They want this information forwarded back to their office by July 15. As you can see, this does not give me a lot of time. Does anyone have any experience in dealing with these requests? Would you be willing to offer any advice?
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CRA
#385691 - 07/13/05 10:32 PM Re: CRA Exam
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Tex I wouldn't make any excuses about the size increase, etc. When you're supposed to have the information, you're supposed to have it BUT instead, I'd call your examiner (should be a number on the request) and let them know you need some additional time. Typically they give you 60 days notice on this stuff. Preface it in such a way that you want to gather the data in a complete package, blah blah, and ask for an extension of a few weeks. I would be pretty suprised if they didn't allow this.

What this then means for you is you are now a full time employee. By full time I mean not 9 to 6, but danged near 24 hours a day if you haven't gotten your ducks in a row for this exam.

If they're preforming a review on multiple years, which include census data from 1990 and 2000 be sure to ask which they will be relying on so you can get a general performance context in place. This requires multiple charts in the back of the exam, and if you're as unlucky as me, basically two complete exam preps (one for each period). One week isn't enough to be ready, and any realistic examiner won't ask that of you.

If they really won't work with you, you can call their omnibudsman, but I'd suggest that be a last, if ever, resort. You don't want to start with an examiner who's miffed at you.

I've answered all of this as if this is your CRA exam. Is it a full blown exam, or a data integrity review? Even for a data integrity review they'll give you more than 4 days to get the information to them. If this is the case, tell them you need to get your data integrity procedures in order, scanned, etc., so you can provide them with the package. Again, they'll most likely work with you. It's the rare examiner who won't no really...I mean that.
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#385692 - 07/14/05 02:52 PM Re: CRA Exam
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
Good advice from Dawnie, as usual. I'm going to guess, though, that the information request is NOT for a CRA exam. The Fed does do some interim monitoring of CRA performance to see if there are significant changes, particularly negative ones, that they can detect before it is time for a CRA exam. That gives them a chance to discuss the changes with management and, perhaps, effect a change that wards off a less than satisfactory CRA rating. But do as Dawnie said and call your examiner. A 4 day time fuse for an information request seems a bit unusual, if not onerous. So, I'll also guess here that they meant to give you until August 15! AR.

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