When the FDIC is asking us for "any CRA self-assessment(s) or an analysis of the geographic/income distribution of loans performed by the bank or other outside organization", would that include HMDA reports?

Yes, they want to see if you have done any self analysis of your CRA program since the last exam. They want to see if you are evaluating your program.

I think they are looking for your analysis of what your HMDA and CRA statements say.

Our bank used to use Integrated Compliance Systems to do a review of our processes, and I do have some documentss from them.

We've also used a company called FinPro to assess the community development needs of the assessment area, their presentation includes a lot of information that is requested in other items by the FDIC.

This whole process is just very confusing.

Frank

If you do any analysis yourself, or you have a company like mine, or others take your data and run an analysis, they want to take a look at the results as it, makes there job a lot easier. It also can speed their exam process.

In addition a self assessment gives you a picture of what the bank looks like before the examiners see it. It allows you to see areas where examiners might pose question and to formulate answers if they should be asked. Self assessments don't necessarily indicate anything is wrong but they do wave flags that indicate you should take a look at something before examiners do, in case there is something that needs attention.

Self Assessments are part of the "We expect the bank to know its story and be able to tell it" mantra examiners expect of banks. You still need to monitor and analyze your data periodically.

Speaking of examiner mantras, the favorite one "is what have you done for me lately?". The quarterly performance of your HMDA data will enable you to show the examiners where you were able to spot weaknesses and show improvement. You always want to be on top of your game. Remember in the examiner's eyes if you tell them, they do not have to tell you.

Enterprise makes an important point. Too many bankers take a passive approach to their CRA PE. They wait for the examiner to rate their performance. The right thing to do is to self-evaluate your performance and tell the regulator how the bank is doing. That has the advantages of: (1) recognizing performance shortcomings in advance and being prepared for potential criticism, (2) showing the examiners you are making a good faith effort to perform under CRA (which can be important if your performance is marginal), and (3) setting the terms under which your performance will be evaluated. Of course CRA lending test parameters are well defined, but by the latter I mean that you can influence the interpretation and use of the performance context data that is critical to forming a judgment about your performance.