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#2255946 - 06/25/21 02:07 PM Needs Assessment
Compliance Nut Offline
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Joined: Feb 2016
Posts: 117
Is it a regulatory requirement to perform a needs assessment of the communities in the Assessment area?

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#2255979 - 06/25/21 05:33 PM Re: Needs Assessment Compliance Nut
Pale Rider Offline
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Posts: 34,318
under the Lone Star
Perhaps only in a round about way, but how would you know if your bank has met the needs of the community if you don't know what they are......
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.

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#2256015 - 06/26/21 04:13 AM Re: Needs Assessment Compliance Nut
Len S Offline
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Joined: Oct 2004
Posts: 1,894
No - although the Q&A's encourage the development of a Community Needs Assessment, there is no requirement. We encourage our clients to develop a CNA because it can capture valuable performance context information and help put a bank's performance into better context.
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#2256020 - 06/27/21 03:34 PM Re: Needs Assessment Compliance Nut
Andy_Z Offline
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On the Net
The requirement and the need are two different things. Small community's with small banks likely have a good idea based on borrower's requests and involvement in the community as a whole. Larger banks in larger areas may need more probing information.

Also ask yourself what happens when your examiners talk to community leaders, businesses and residents and ask if your bank is meeting the needs, what will they hear, and how is your bank doing at meeting that metric?
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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