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#1658258 - 01/31/12 03:12 PM Documentation Format Question
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Joined: Aug 2002
Posts: 133
Our regulators from the OCC gave us a Qualified Investment Worksheet, a Qualified Service Worksheet, and a Qualified Community Development Loan Worksheet. We were told to fill one out for each of our services, investments, community development loans. We are a large bank. This seems like a lot of paperwork for small donations of $50, $100, etc. Are other banks doing this? Are there regulators out there that could speak to this issue? Will regulators really go through the binders of paper that we are creating. My thought was to put that same information in a spreadsheet. That way it can be sorted by assessment area, etc. Then supporting documents could be kept in a binder if the examiner has questions about the issues. If examiners want the worksheets, could it be for only those over a certain dollar amount of those that we want to be given the most attention. If I could get a regulator's point of view or an experienced CRA expert, I would really appreciate it. This seems just common sense to me but, in the past, our institution has been told to complete the sheet on EVERY service, investment, etc. Trying to improve efficiency and stop killing trees.
Opinions do not reflect opinion of employer and cannot be relied upon as advise.

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#1658476 - 01/31/12 06:42 PM Re: Documentation Format Question JUST CALL ME CRA
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Yes they will go through the binders during an exam to verify that each investment or donation qualified.

That is not to say that for smaller donations you couldn't put the same information in a spreadsheet. You do have to describe the organization, the dollar amount, why the organization qualifies for CD credit, etc. If you have further supporting documentation you can reference the binder.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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