How often are CRA exams for large insitutions with a satisfactory on their last exam? I was thinking every four years, but have my doubts. Thanks!

2 years, although it may be changing with the new rules.

It may be different from agency to agency - but we were told to expect one every three years with a satisfactory (OCC). You might get it postponed another year for an outstanding. Then again, they might decide to come in more frequently for some other reason!

We are OCC and went 3 years when we were satisfactory. Now that we are outstanding, I hope it will be longer.

The FDIC frequency is every 30 months. This will be unchanged for Intermediate-Small Banks

A sneak peek at the materials for tomorrow's FDIC Dallas Region CRA webcast shows this exam schedule for ISBs:

24-36 mos when compliance rating is 1 or 2 and CRA rating is Outstanding or Satisfactory;
12-24 mos when compliance rating is 3 and CRA rating is OS, S or Needs to Improve;
12 mos when compliance rating is 4 or 5 OR CRA rating is Substantial Noncompliance.

Popeye's comment about the exam schedule is interesting because I was told by Robert Mooney, FDIC Assistant Director and Chief, CRA and Fair Lending Policy and Examinations at the ACB Compliance Conference in Chicago last month that the regulatory agency couldn't change the exam frequency for IS banks and that it would continue to be every 30 months as it is for large banks. I won't be able to listen to FDIC webcast so I would be interested in hearing what is said.

Len - it's possible I took that particular PowerPoint screen out of context. I'll get back to you after the webcast today.

Thank you Popeye. From what I understand the regulators are hamstrung on this issue. But who knows, maybe something has changed. Anyway I find that we all help one another out on threads and it is a great resource.

That was me Popeye, I forgot to sign in! Looking forward to hearing what you learn today.

I've never seen a 30 month schedule. We are examined every 3 years (OCC). Exam schedules do vary from bank to bank, but KC, don't expect to go to five years as a large bank with an outstanding. You'll stay at 3 years

The question of CRA exam frequencies gets a bit muddled because of statutes and individual regulatory agency policies.

For banks under $250 million at their last CRA exam that were rated Outstanding or Satisfactory at that exam, the CRA cycle is still governed by the Gramm Leach Blilely Act. That's what pegged the CRA cycle for Outstanding banks at not less than 60 months, and 48 months for those rated Satisfactory.

For banks over $250 million at their last CRA exam, the regulators are not "hamstrung" on the CRA frequency. The CRA cycle policy for these bank is at the discretion of the regulators. It seems to be ranging anywwhere from 24 to 36 months. AR.

Our regulator is the OTS. We were a "large bank" at our last CRA exam, which was 36 months ago. We received a Satisfactory rating. We are now a "small bank" under the OTS's definition. When should be we expect our next CRA exam?

Call your regulator Anon. There is no better answer than that. They aren't nearly as evil as they look some are even friendly if handled with proper care.

Yesterday's Dallas Region FDIC webcast confirmed this exam schedule for ISB banks.

Quote:

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24-36 mos when compliance rating is 1 or 2 and CRA rating is Outstanding or Satisfactory;
12-24 mos when compliance rating is 3 and CRA rating is OS, S or Needs to Improve;
12 mos when compliance rating is 4 or 5 OR CRA rating is Substantial Noncompliance.

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