Several years ago we had a bad CRA Exam. It wasn't necessarily because we were doing badly on the goals of CRA but that we were not prepared to show the examiners what we were doing. We also had no available program to help us shore up any weaknesses we had, and show us what we had to spend extra effort on. When the examiners came in, we said, here ya go...no explaination, no nothing. Golly gee, it didn't go well.
Had we spent a little cash, we wouldn't have been blindsided by the examiners results. We would have seen our stregnths to highlight, and any perceived weaknesses to discuss or explain to the examiners. I've looked at the data for the bad exam...I think we were doing ok, but didn't know what to discuss with our examiners due to a lack of information. How on earth do you present yourself when you have no idea where you stand?
We spent the cash the next year. (I was not with the bank during either time).
I had a goal of Outstanding during my first exam with this bank (my first exam ever as I come from a lending background). I was able to pull reports from the CRA Wiz that showed me exactly where we stood with the regulation. (Well exact as you can be with the vagaries of CRA). For instance, I can pull a report that says my overall market share in home purchase loans during a specific period of time is 3.62%. In low income geographies I am actually taking 5.48% of the market share and in moderate income geographies I'm at 6.49%. This means..I rock (ok my lenders do).
On the other hand, there are 2.04% owner occupied units in loa income geographies in this same area. What if only 1.03% of my loans went to those geographies? I'd need to explain that to the regulators. Perhaps a special program focused on those geographies dried up, or housing was so tight that homes just weren't available to meet the needs? Or a transient population had discontinued in that area (a large employer closed thus removing 500 laborers who used to live and work in the geography) and home sales were in a complete slump, but I'd put together a program to assist new residents...which was not yet showing in the numbers?
This is the kind of information I get from the program I've purchased. I know that there are other programs out there that do the same thing. It's sometimes not so much what you do, but why, how and whats behind what you do that matters in an exam. A low figure can be supported and presented as a positive IF you know it's there to deal with. With no abiltiy to discover this...you're blind at exam time. I'd be scared to death to be in this position.
I can manipulate the data to cover many different areas, periods of time, products, etc. Marketing can use the data as well for product development. Spending this money keeps me up to date on where we sit, and where we need to scootch over to on occasion
Not spending it...could leave you with less than satisfactory results in examinations. You could be just like us...we're Outstanding...and frankly I think we've been Outstanding for many years but we just didn't know how to share that with our examiners.
Whatever you do...get something! I recommend the program my examiners use because I like to see what they see, but it does have some flaws. I think they all do from what I've heard.
I hope that helped. If I were you, I'd start calling the companies that provide these programs and ask them for some samples to show your board. Sometimes that is all it takes.
My board is behind me, and wants another Outstanding in the future. They understand that this isn't free, but it's worth the money in the long run!