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#2118060 - 02/13/17 09:16 PM CRA policy
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 146
is it a requirement to have a CRA policy

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CRA
#2118217 - 02/14/17 07:52 PM Re: CRA policy Compliance Action Subscriber 1226
RR Jen Offline
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RR Jen
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Running and riding everywhere ...
There isn't any language in the regulation indicating a policy requirement that I'm aware of, but with the other various requirements I wouldn't want to operate without one.
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#2118311 - 02/15/17 03:24 PM Re: CRA policy Compliance Action Subscriber 1226
Compliance Action Subscriber 1226 Offline
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Joined: Sep 2015
Posts: 146
OK thank you

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#2208761 - 03/14/19 04:44 PM Re: CRA policy Compliance Action Subscriber 1226
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,113
My bank has a CRA policy. Does it need to be approved by the Board annually? I would only like to send it to the Board if changes are made, such as a change in the CRA Officer.

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#2208763 - 03/14/19 05:11 PM Re: CRA policy Compliance Action Subscriber 1226
MScarn6942 Offline
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Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
I wouldn't include the specific name of the CRA Officer in the CRA Policy. Just say you'll appoint one. I'm not sure on approval.
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#2208792 - 03/14/19 08:07 PM Re: CRA policy Compliance Action Subscriber 1226
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,724
The Mitten State
Our CRA Policy is approved at least annually by the board.
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#2208797 - 03/14/19 08:38 PM Re: CRA policy Compliance Action Subscriber 1226
Norman Paperman Offline
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Norman Paperman
Joined: Aug 2012
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Just my two cents on board approval of policies... They don't read those things. They couldn't score 20% on a quiz covering the content of X policy.

The prevalence of policies being approved by boards, in my opinion, is far too much.
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#2208815 - 03/14/19 11:41 PM Re: CRA policy Compliance Action Subscriber 1226
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,113
Norman Paperman.....I couldn't agree more! That's why I'm re-analyzing this whole activity trap. What really needs to be approved and how often. If anyone has a list, please share.

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#2208833 - 03/15/19 02:43 PM Re: CRA policy Compliance Action Subscriber 1226
CRAWilson Offline
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Joined: Oct 2010
Posts: 7
Ohio
My firm has a CRA Statement.

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