There seems to increasing boldness in the nonprofit CRA world to protest bank mergers and acquisitions. This definitely looks like a return to the past, EXCEPT, that this time, it's organized around extracting CRA plans in addition to CRA commitments. CIT and Valley National Bank are two more recent examples of this.

Perhaps it's my CRA bias frustration, or ignorance, but where in the regs, Q&A, or law grant regulators the authority to impose on banks the development of a CRA plan. While it may not be prudent or practical to say " Thank you, but no thanks" to developing a plan, can we look to the regs/Q&A or other source for guidance?

I appreciate your feedback.

It will be negotiated case by case to resolve perceived shortcomings or desired enhancements in the existing program.

The regulators need to appear as though they are responding to the complaints. So, we have to include a few commitments and promises. It is all part of the cost of merging and expanding through the opening of branches. It is part of the "privilege" of having our deposits insured.

At a very large bank (for its time back in the 90s) - in Philadelpha - the bank was extremely engaged with its communities, including very low income areas. This bank really did a lot, it was just part of the corporate culture. When the bank was selling to a larger out of area bank, the protests started that these communities would be severely impacted. A very large fund had to be set up by the acquiring bank, earmarked for certain areas, and that fund still exists today! (I always check.)

So, in reviewing the CRA law, the regs, AND the Q&A, i don't find evidence of mandating a cra plan. In fact, i'm seeing clear evidence that community groups (and regulatory ageicies) are forcing upon banks the type of CRA Test under which THEY will be evaluated. Here's is why. The march to mandating CRA plans, is the establishment of a defacto Strategic Plan model for evaluating performance. If this is true, then, why have a large bank, ISB, or Small bank test?? I fullly understand that regulatory ageicies want to be preceived as being proactive, but to do so, they are sidstepping their own regulations. In the final analysis, my myopic focus is that CRA plan mandates are an insidious way to force banks to adopt a exam process that is NOT their own choice. Furthermore, it places tests in the laps of community groups and not the banks.

" I fullly understand that regulatory ageicies want to be preceived as being proactive, but to do so, they are sidstepping their own regulations."

Regulators have a tendency to interpret regulations in their unique ways. Look at the following forums for examples: Fair lending, CRA, RESPA, Loans, Examinations, BSA, Flood, Need to Remain Anon, They are littered with regulators legislating from the field.