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#473006 - 12/20/05 09:13 PM Starting with CRA
BankerJohn Offline
New Poster
Joined: Nov 2005
Posts: 23
Mississippi
Hi. I work for a <200 million community bank, in a loan office in a community where our Bank is building a full service branch. I am also new to banking, having come from the consumer finance field. I have been named compliance officer for the branch and CRA officer. We have some loans ($7 million) and my boss who has limited knowledge of CRA wants me to start a file for CRA in our office. Any suggestions on where to start and what sort of information I would need to have on file, other than our loan information. Thanks

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CRA
#473007 - 12/20/05 10:16 PM Re: Starting with CRA
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Welcome to banking and CRA. If this is a Branch Bank then "The Bank" should have a Compliance Officer for the bank as a whole. It is unusual to have a "Branch CRA Officer"

If this is a branch and you have been asked to follow CRA issues then contact the banks compliance officer and see what they expect you to do.

If you have been appointed as the banks CRA Officer then no one has done you a favor, as it really requires a person that has a good understanding of banking to handle all that is required.

In order to answer more completely let us know if you are the banks CRA Officer or someone the branch manager has asked to coordinate things in the "Branch"
_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs

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#473008 - 12/20/05 10:25 PM Re: Starting with CRA
BankerJohn Offline
New Poster
Joined: Nov 2005
Posts: 23
Mississippi
I'm coordinating in the Branch. Yeah, I got surprised with compliance, but in consumer finance we had to be strict on policies, procedures, and paperwork. We dealt with lawsuits and all sorts of fun things daily. I called the HO and we are getting some info sent to us to start our files. SInce we are in another community from HQ, we will keep up with our info here. THanks for any help.

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#473009 - 12/20/05 10:41 PM Re: Starting with CRA
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
The good news is you are not responsible as the "Banks" compliance officer. Your main function will be to follow the policy and procedures handed down from the compliance officer to you.

Learn the banks procedures and policies. Read the regulation, ask questions,

From a CRA standpoint understand the defination of a Small Business/Farm loan and the data that is required.

Find out if you have a cra "Public File" in the Branch or a notice of where a person can review the banks public file.compliance. Understand what's in the public`file.

Understand what the banks assessment area is and the effect it has on CRA

Understand what a Community Development loan or activity is and make sure the Compliance Officer office knows of these activities and loans.

Your bank is still considered to be examined as a "Small Bank" read the examination criteria for a small bank.

CRA is just one small part of "Bank Ccompliance" See if you can attend seminars or training. BOL has excellent programs and resources available.

The most important " Develop a positive and strong relationship with the banks compliance officer. Learn as much as you can from them.

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#473010 - 12/21/05 03:00 PM Re: Starting with CRA
BankerJohn Offline
New Poster
Joined: Nov 2005
Posts: 23
Mississippi
Thanks for the input. I have been on this website a lot lately, and I have learned as much from reading posts as I have from reading the articles. Thanks again.

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#473011 - 12/21/05 03:19 PM Re: Starting with CRA
CubDave Offline
Diamond Poster
Joined: Oct 2005
Posts: 1,562
BankerJohn - when I switched from banker/lender to the head of marketing, CRA came along with the job. I didn't even know what CRA stood for and my predecessor left in a matter of 3 days and spent about an hour showing me boxes of CRA files.

I literally spent days and days reading those files, perusing various websites including FDIC and FFIEC. I called my local FDIC office and set up a meeting with their community affairs person. I looked at other bank's Public PE's (after I learned what the heck that was).

Then I found BOL, which turned out to be an incredible resource with people like Dawnie, Len and others, and especially Don Narup who was incredibly helpful and turned into a great resource from whom I had map work and demographic assessment work done.

Of course now, 7 years later, although I officially still hold the ceremonial title of "Chariman of the CRA Committee" (which includes Board Members), I officially got to pass off my CRA Officer title to seomoen else, and I very nicely passed along all of my files!!!!

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