I am preparing a brief "article" of sorts for our organizational news letter. We have had issues with personnel omitting or inputting incorrect data on Applications. It then becomes a chain of emails back and forth requesting the same data corrections seemingly every day. I will cover this, but want to also take the opportunity to provide pertinent basic information. There is not a significant amount of CRA knowledge in our organization, so I want to have a few basics that pertain directly to Lenders day-to-day operations in the article. If you were sending out CRA basics in an article like this, what points would you make sure to drive home?

This article will need to share space with a section on HMDA, so it does need to be somewhat brief.

Any and all advice is welcome. I am new here.

How big is your institution? What CRA exam protocol are you measured against?

I apologize for omitting the most pertinent data that I could. Perhaps I should have been a Lender. I am very new to CRA and Banking as a whole. I have less than 2 months experience in CRA data.

Large Bank
Lending, Investment, Service

Does this provide more clarity?

The failure to pass a CRA exam can have a very devastating impact on a bank. So CRA performance should be of the utmost importance to a bank, starting at the very top.

Essentially, CRA is all about meeting the credit needs of the communities you have designated as your Assessment Areas. It's all about lending. For a large bank that means showing you are extending an adequate volume of credit (loans) within what you have told regulators are your markets. Moreover, you must show that you are meeting the needs in the low- and moderate-income tracts and of low- and moderate-income borrowers as well as very small businesses (<=$1 Million GAR).

You also have "community development" responsibilities which include lending, investing, and servicing.

It's impossible to give a course on CRA in a few paragraphs. All too often senior management looks at CRA as just another unnecessary regulation - until they get hit with a "needs to improve" rating. If you don't feel comfortable with your understanding of the Regulation you should insist that management pay for you to get adequate training so you can fulfill your CRA responsibilities. The worst feeling in the world is going into a CRA exam and not knowing what to expect (unless you are a masochist!).

BTW, it's not unusual for commercial loan officers to fail to cooperate - they're too busy pursuing loans. Senior management must instill in them that collecting data is not an option - it's a must.

We do online CRA training and so do other consultants so it doesn't have to be expensive or time-consuming to get educated. For your own piece of mind, I suggest you aggressively request such training.

I second Len's comments. Good data is critical for CRA success.

My latest strategy for repeat offenders who don't capture the data correctly is to pick up the phone, call them and have a conversation about what I need, why I need it and what happens to the bank if they don't get it right.

When you email mail them, it's too easy for them to ignore it or forget for the next time. The actual verbal conversation seems to stick in their minds better. And talking it out makes them truly understand why we need the data. OR maybe they just don't want YET another phone call from me in the future, Ten minutes of me talking to them is ten minutes that can't spend selling....so they try harder :-)

Thank you for the very thorough and thoughtful response! I am still on the front end of things learning wise, so your post is incredibly beneficial to me. Thanks!

I used to send out "Compliance Quickies" which were 1 page memos on a frequent topic. But this allowed me to target New Accounts, or Loans, or Loan Admin as examples so everyone didn't have to review it. It was common that these areas had regular meetings like before the bank opened. They could review and discuss the specific issue with applicable codes and descriptions other readers may not understand and they could walk away with a copy if needed. I found this quite helpful to target the problem with the solution.