I was looking for something in the Reg about the CRA Policy and what it needs to contain (specifically if there is anything about how often the BOD needs to be updated on CRA performance)but I didn't see anything. I did a search and it looks like maybe the CRA policy requirement went away some time ago...is this correct? If anyone still does the policy anyway is there a standard on updating the BOD - ie: at least quarterly?

This is my first full year working with CRA - and our last year to report as a small bank. Assets went over $250 million in 2003, so we begin collecting data for large bank reporting on January 1, 2005, and I am totally lost. If you are reporting as a large bank, do you have any suggestions? I have to meet with our Executive Committee soon and present an overview of our procedures for reporting as a large bank - procedures that do not fully exist at this point.

If your assets have been over $250 million for two years starting on January 1 you must begin collecting CRA data.

Shannon and Anon, you can pm me (anon you'll need to register) and I'd be happy to email you a copy of my CRA policy.

No it's not required any more, but it's a valuable document to have on hand. It shows your examiner that you have a handle on your bank's CRA program and gives your Board and senior management a roadmap to follow. It also is a nice brief document covering everything from Assessment Area, Data Collection to Sunshine.

I spent quite a bit of time putting ours together. Once it's complete all you have to do is change the date annually and any assessment or regulatory changes can be addressed and it's complete for that year. Our board recertifies it annually.

I used Dawnie’s CRA Policy as a starting point for creating one for my Bank and it was a great help. Thanks Dawnie! Definitely PM her and get a copy. If you want to see mine you can PM me too.

Excuse my ignorance.....what's a BOD?!?!? and Dawnie can I have a copy of your policy too?!?! We just created one, and I want to see if I missed anything.

I'm assuming PM means personal message....so I'll try that route.

I'm assuming BOD is Board of Directors

Yes, my apologies, I did mean Board of Directors.

Thank you, and I now know that PM stands for Private Message.

and CRAP stands for CRA Policy

This is my first full year working with CRA - and our last year to report as a small bank. Assets went over $250 million in 2003, so we begin collecting data for large bank reporting on January 1, 2005, and I am totally lost. If you are reporting as a large bank, do you have any suggestions? I have to meet with our Executive Committee soon and present an overview of our procedures for reporting as a large bank - procedures that do not fully exist at this point.

Anon, my policy does cover reporting and data collection as well as who is responsible for each, etc. If you'd like to email me at DCoursey@FNBAlaska.com I'd be glad to share it. We are a $2 billion bank (so yes we're large)

Does anyone who has been reporting as a large bank have a CRA Policy that I could get a copy of? Do you use special software designed for CRA/HMDA gathering/reporting? If so, which are you using?

I use PCI Wiz Lin. And I just sent you the policy

Would you be willing to email me a copy of your CRA policy?

Sure, just tell me where to send it?

Send my copy to lmiller@mtcbank.com

Thanks

Linda

Please help...I am new in the compliance world and have been given the responsibility in our Bank to come up with a CRA Policy. I am still researching what CRA is all about!!! If anybody is willing to email me a example or copy of their CRA Policy I would be most grateful. I feel as if I am way over my head.

My email address is cstrich@lcbt.com.

Thank you all in advance

Oops...my email address is ckstrich@lcbt.com

Linda and Compliance Newbie. Recognize that you are responding to a post that is over a year old. And while Dawnie would do this if she could, as she is still active here, she isn't at work now and is dealing with more important issues. She'll be back. But my point is, don't slow your efforts waiting for a policy from Dawnie.