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#1312947 - 12/23/09 09:45 PM CRA reports
Trees Offline
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Joined: Apr 2005
Posts: 4,013
I know we have to prepare docs. for the regulatory examiners when they visit. I don't see where we have to prepare/send any interim reports to the Feds or otherwise....am I right? I am seeing something about a February report....what's that?

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CRA
#1313066 - 12/24/09 12:49 AM Re: CRA reports Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Just the annual submission if you are of a size that it is required, or you file voluntarily (March 1 submission date).

Other than that there are no interim reports unless the bank was rated needs to improve or unsatisfactory.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1313234 - 12/24/09 03:21 PM Re: CRA reports Kathleen O. Blanchard
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Annual submission as in a separate document in addition to dealing with first day letter requests, right??? If I want details on what is required for this report, where would I find it?

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#1313251 - 12/24/09 03:34 PM Re: CRA reports Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
What asset size is your bank?

The CRA Guide (similar to HMDA Getting It Right), FAQs, link to FFIEC submission software, etc. is all right here:

http://www.ffiec.gov/cra/default.htm
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1313406 - 12/24/09 05:34 PM Re: CRA reports Kathleen O. Blanchard
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Assets below $1 billion. I know banks had the option of filing large bank or intermediate large....I think we went with large.

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#1313540 - 12/24/09 08:33 PM Re: CRA reports Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
if you went with large you must have your submission in by March 1.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1313669 - 12/28/09 03:29 PM Re: CRA reports Kathleen O. Blanchard
Trees Offline
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Joined: Apr 2005
Posts: 4,013
OK, I am going to review the reg today and that FFIEC CRA guide. can I assume that I will find everything in either of those two documents as regards what has to be submitted and when? I hate it when someone leaves a job and they don't arrange to have the replacement work with that person....

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#1313728 - 12/28/09 04:42 PM Re: CRA reports Trees
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Depending upon your submission method/submission software, a review of the file specs might be useful.

http://www.ffiec.gov/cra/fileformats.htm

If you use the FFIEC software, the help file has useful info as well. Otherwise, the software that your bank uses should have helpful info available.

Come back here if you get stuck and we will all be glad to help you out.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1313830 - 12/28/09 05:48 PM Re: CRA reports Kathleen O. Blanchard
Len S Offline
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Joined: Oct 2004
Posts: 2,090
Connecticut
Any bank below the "Large Bank" threshold of $1.098 billion is not required to file an annual CRA report, although we encourage all our clients to voluntarily do so because (1) it preserves your elective to be examined under the Large Bank examination standards and (2) it is impossible to monitor and manage your CRA performance if you don't collect the information. Is there anyone who wants to be held accountable for performance about which they have no information? - but that is exactly what many CRA officers are expected to do if they are not collecting their CRA information.

When you file your information you complete (1) a "record" (sometimes called a "panel") that contains information about your institution, such as name, RID, etc., (2) a record that summarizes (aggregates) your small business lending activity, (3) a record that summarizes your small farm lending activity, (4) a record that summarizes your community development lending and (5) a record that summarizes how you delineate your assessment area(s). All details pertaining to your small business and small farm lending are maintained (but not reported) in the "micro-data" record if you are using the FFIEC CRA software (and most commercial CRA reporting software).

When examiners arrive for your CRA PE they will examine the micro-data file. You will be expected to have scrubbed your data to assure its reliability. Otherwise, examiners will develop a sample of your lending and that sample will be the basis for rating your performance (this is another reason to collect, scrub and monitor your data - otherwise your rating will be based on a sample that may or may not accurately reflect your true performance).

On the GeoDataVision website there is a free recorded webinar that teaches you how to prepare for an impending CRA exam. Also, there is a CRA Exam Checklist in pdf document format that you can download.
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