Good afternoon! We're preparing for a Compliance and CRA Exam that's right around the corner, postponed from June 1. I'm curious who has had a compliance exam in this current environment and how it's changed the examination approach. What are they more focused on? We're a Fed bank. The agencies issued the guidance for examiners on safety and soundness in response to COVID but, I haven't seen or heard much specifically from the compliance standpoint. Also putting together our CRA "Story" so input as to what you've included would be helpful to determine full-story approach.

We are having our CRA/Compliance exit this afternoon. We're FDIC and 2.1B in assets. The remote exam was almost surreal, as we only talked with the exam team maybe twice a week.

They went very high level on loan review, as their samples were 8 TRID loans, 2 HPML loans, 10 denials, 3 credit cards, and 3 HELOCs. Oddly, they seemed to focus on how credit card payments we applied, specifically, compliance with 1026.53. We hadn't seen that before.

They reviewed any advertised benefits on any accounts to make sure that the customer received the benefit. That's been a huge focus the last two exams for us. Anything that looks like customer harm is a priority.

For our CRA story, we included all our PPP loans and the jobs retained, the waived extension/modification fees, payment deferral programs, etc.

Thank you and good luck! I'd love to know more about the feedback given at exit!

I am also preparing for an upcoming FDIC/CRA Exam - 11/30. I'm curious as to how FDIC looked at the PPP Loans and opinions about GR for these loans. We did not collect GR and reported a "3" revenue category. Unfortunately it puts us way below our peers for analysis. So are the examiners going to count this against us?