As the CRA officer, who do you communicate with as far as proposing CRA investments for funding, etc. marketing committee?
Would you be willing to share the memo that you would propose CRA investments?
Thanks .

We have a capital markets person on our CRA committee and I also confer with the CFO on investment objectives. I try to find investments that do not add credit risk - no staff to manage that - and at least a small return to add to cash flow (or to add to the investment if reinvested). I try not to veer off from the bank's investment goals. In an extremely large bank, you can have your own goals. In a smaller large bank or small bank, you don't want to make investments that will cause treasury issues. I am currently exploring equity investments in CDFIs. I can get a small return on my investment as well as CRA credit. I have also found that it is not worth it to try to decipher CMOs on your own. It is better to let a fund like CRA Fund select them for you. They know what they are doing. You are taking a chance that all of the mortgages are eligible and hoping you get the mortgages you selected from the pool. Not worth the work it takes. I would rather pay CRA Fund and similar groups for their expertise. You get what you pay for. I also am working on a policy that allows me to reinvest principal returns and interest earned on CRA investments. It makes it more palatable to management trying to balance the bottom line and CRA obligations.

Local groups, CDFIs, CRA Fund, etc. are happy to come in an meet with your bank.