Do any of you have a state imposed CRA? If so, what is required? Have there been any federal preemption issues that you know of? In other words, has the OCC claimed that the CRA requirements are preempted by federal law?

Massachusetts has its own community reinvestment provisions built into its banking supervision laws. It only applies to state-chartered banks, but applies to state-chartered credit unions, too.

For Massachusetts banks, this means being subject to CRA exams both from the FDIC or Fed and the Commissioner of Banks. When we were a state-chartered bank, it seemed that the FDIC and the state worked fairly well off each others' efforts, and the dual exams (at least for CRA) didn't seem terribly onerous.