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#16003 - 04/23/02 12:54 PM Upcoming CRA Exam question
Some Days You Just Can't Win Offline
Gold Star
Some Days You Just Can't Win
Joined: Feb 2002
Posts: 461
Mississippi River Valley
We are considered a large national bank and are preparing for a CRA exam. None of us that are here now have been involved with preparing for an exam before as our previous compliance officer handled all details.

The letter we received from the OCC asked for alot of information. We have most of it compiled and are ready to assemble it. My question is how are any of you presenting the information?

Do you put it all in one binder or multiples?
Do you break it down by subject:
performance context, lending, service, community develpment? It seems to me that if you break it down, you would have alot of duplicate information/pages as many items pertain to several areas.

If anyone has insight as to how to present the information, or any other helpful information you would be willing to share, it will be appreciated.
How long a minute is depends on what side of the bathroom door you're on.

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General Discussion
#16004 - 04/23/02 02:31 PM Re: Upcoming CRA Exam question

My advice: Ask you regulator what format they would like have the information presented. Not only do you begin a good rapport that will carry through the exam, but you may even get them out of the bank a little faster if the information is organized consistent with how they do their on-site work. I've had regulators prefer binders and then some that preferred file folders. My preference and current system: a series of binders for each component of the exam: Service, Lending, Investments. There are cover forms describing each transaction or activity encased in a plastic sleeve within the appropriate binder, and then supporting documentation contained within the sleeve. Yes, I am duplicating some of the information that can be used in another category, but if you keep up with this throughout the year, it's not a huge deal. For example, a contribution and service activity to the Habitat for Humanity may have the same supporting documentation regarding the mission of the organization, etc. I would copy the information for inclusion in both the service binder(s) and the investment/donation binder(s). Additionally, a comprehensive performance context piece is written and presented to the EIC at the beginning of the exam as a self-contained document. Then, as a "reminder", if you will, applicable sections of the performance context relating specifically to our service, lending or investment performance are included at the beginning of each binder.

Good luck and good results!

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#16005 - 04/23/02 03:26 PM Re: Upcoming CRA Exam question
JMB Offline
Joined: Mar 2002
Posts: 59
I always took their letter and used multiple binders. Each item was indexed and tabbed.

If an electronic file was requested, I put it on a disk and put that in the tab with a description of the information.

Finally, I kept a binder so that they did not have to stand at the copier for copies. (Yes, it killed a lot of trees, but this way I knew exactly what they had been given).

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#16006 - 04/23/02 05:41 PM Re: Upcoming CRA Exam question
I Wear Many Hats Offline
Platinum Poster
I Wear Many Hats
Joined: Mar 2001
Posts: 591
the beautiful state of ME
We are also a large bank under CRA regulated by the OCC. We had our first large bank exam last year. All of my information was in file folders and labeled by the # on the request list. It was my experience that they also like to see some things electronically so everything (with the exception of our public file) was also available in electronic form. What you may want to do is find out in advance who your CRA examiner will be - if you don't already know - and contact them directly. Our CRA examiner came up at a different time than the rest of the crew and did want to see files electronically ahead of time. GOOD LUCK

all opionions are my own and not necessarily that of my employer.
The paradox of planning is nothing happens....

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