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#18286 - 05/21/02 03:46 PM CRA
bean Offline
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Joined: Mar 2002
Posts: 225
I am looking for CRA help. I have been asked to find out if anyone has developed or is using some type of action plan for CRA. Also I am looking for some assistance on how others do self-assessments for CRA.
If anyone can guide me in the right direction I would appreciate it.

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General Discussion
#18287 - 05/21/02 04:06 PM Re: CRA
Michelle D Offline
Gold Star
Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
I just completed a "self-assessment" prior to our exam (in reality this should be completed at least annually but I just assumed CRA responsiblities 1 month prior to the exam).

What I did was identify who my institution considered its peers and then who the regulators considered our peers and any institution that had recieved an "outstanding" in our region and pull their P/Es from the regulator website. I also reviewed our prior exam and recent minutes/documentation from the Bank's CRA committee to make sure I understood any goal (lending, investment, service) that the Bank had. This information could be housed in Board minutes, loan committee minutes and/or any other committee that may discuss these issues - you need to find it all.

Once you have all of the information, you need to gather your Bank's data (lending, investment, service) and start to analyze it. I used the charts that my regulator had used in the P/Es to determine what to look at for lending and benchmark our performance. For investment and service I benchmarked our "offerings" against the peers and provided a discussion document to management on where we needed improvements. (We didn't have time to prepare 2 documents so any "critisms" we handled outside of the document via discussion documents. Out of these discussion documents came goals for investment and service.)

Finally, I wrote a narative that explained the results. I also made sure to identify anything that made me different from my peers and to point out the unique atributes that my bank brought to the market.

The document was well received by management and the regulators. They basically used my document to create the P/E.

This was a major project and took most of a month, but the CRA exam was a piece of cake because the examiners had everything they needed and required minimal "hand holding".

Hope this helps.

Good Luck
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The opinions are mine and do not necessarily reflect those of my employer.

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#18288 - 05/21/02 06:56 PM Re: CRA
bean Offline
100 Club
Joined: Mar 2002
Posts: 225
Michelle:

Thank you very much for the extensive info. However since I am new to compliance as far as actually having to monitor it, I am unfamiliar with some of the terms you used. What did you mean by P/Es and what regulator site did you pull them from?
I have never developed a discussion document, but that sounds like something we need to do. If you can tell me what that document would contain that would be helpful.
Thanks alot

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#18289 - 05/21/02 08:36 PM Re: CRA
Michelle D Offline
Gold Star
Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
Who's your regulator? On each regulators website there is a link that you can use to get other banks' (regulated by that regulator) Performance Evaluations (P/Es). Performance Evaluations are the public documents that the regulator issues after completion of an exam and the bank is required to place in its CRA Public File.

A discussion document is really a memo that you use to outline the bank's weaknesses and your ideas to improve performance. The point is that you are trying to get a discussion going as to imposing "your" ideas. That's why this document comes after you have completed your analysis because you have to have facts to support the conclusions to get the outcome you want.


FYI when checking out the regulators' sites look in the CRA sections to find the P/Es.

Good Luck
_________________________
The opinions are mine and do not necessarily reflect those of my employer.

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#18290 - 05/21/02 08:40 PM Re: CRA
Bartman Offline
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Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
Michelle beat me to the punch. The only thing I'd add is a website for CRA ratings - the FFIEC maintains the database, and this is a great place to start your search for public evaluations:

http://www.ffiec.gov/cracf/crarating/main.cfm
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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#18291 - 05/21/02 09:10 PM Re: CRA
JulesB Offline
Gold Star
JulesB
Joined: Feb 2002
Posts: 324
A Designated Tree City in OK, ...
Bean,
You don't state whether you are a "small" (under $250 million total assets), or "Large" bank for CRA purposes. There are different standards that the regulators look at for the two types. They also have "wholesale" and Strategic plan" options, but the most common are the large and small. As far as doing a self-assessment, I would look at the procedures used by your regulator. Like the others have said, it also helps to see what the other banks in your area received in their last CRA Performance Evaluation.

You also need to find your bank's CRA Public File and make sure it is up to date. The CRA regulations from each agency contain a list of what should be in the Public File. Hope this helps too.
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Responses are mine, and are no reflection of my employer.

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#18292 - 05/21/02 09:12 PM Re: CRA
GenerousLife Offline
Diamond Poster
Joined: Feb 2002
Posts: 1,466
USA
We recently had our CRA exam (my first). The regulator really appreciated a narrative that I prepared about our community. Items such as new industry (or lack of), availability of higher education, etc., all those things that are unique to the community and how our bank interacted with them. It also shows the regulator that you are really thinking about CRA.
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"No problem can withstand the assault of sustained thinking." ~ Voltaire
"Sustained thinking gives me a headache." ~Me

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#18293 - 05/21/02 10:36 PM Re: CRA
Michelle D Offline
Gold Star
Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
Bean, just one caution on the FFIEC website. I agree with Bart that it's a great place to start, but .... (there always is one) Use the site for institutions examined by your regulator and in your region.

My caution is that regardless of what the regulators say - each regulator and indeed each region within that regulator have different points of view. While those points of view may not change the rating on an exam - it can make the exam more time intensive than it needs to be.
_________________________
The opinions are mine and do not necessarily reflect those of my employer.

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