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#64407 - 02/27/03 10:09 PM CRA- From small bank to large bank
jbest Offline
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jbest
Joined: Jan 2001
Posts: 134
My bank is changing from a small bank to a large bank status for CRA. We are also going to be a HMDA bank sometime this year. I have been given the honor of being the CRA Officer. We have no job description for that position. Would anyone be willing to share a job description and their CRA Policy. It would greatly be appreciated. My e-mail address is jbest@1stbanknet.com

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General Discussion
#64408 - 02/27/03 10:17 PM Re: CRA- From small bank to large bank
Anonymous
Unregistered

RUN - RUN FAST - or start shrinking those assets! In seriousness though - I inherited the job myself and just learned on the fly. No description to help - sorry.

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#64409 - 02/27/03 11:04 PM Re: CRA- From small bank to large bank
RebekahL CRCM Offline
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RebekahL CRCM
Joined: Feb 2003
Posts: 766
Big Sky Country
My bank also just finished the two year transition period and is now classified as a large bank, too. We don't have a CRA policy, either, and I have also just been learning everything on my own. We are not a HMDA bank yet, though.

I recommend www.ffiec.gov as a primary resource. Their "Guide to CRA Data Collection and Reporting" publication is very helpful. Also, that's where you can download FREE software for your CRA recordkeeping, and also do FREE geocoding for your loans.

Good luck! Before long, if you get as sick of it as I did, you'll be certain that the acronym "CRA" is missing a letter from the end - "P".

p.s. utilize this forum often - there are some real CRA experts here!
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#64410 - 02/27/03 11:08 PM Re: CRA- From small bank to large bank
c.a.r Offline
Gold Star
c.a.r
Joined: Oct 2002
Posts: 377
Texas, USA
I have been researching and can not find what makes a small bank or a large bank?
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#64411 - 02/27/03 11:28 PM Re: CRA- From small bank to large bank
RebekahL CRCM Offline
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RebekahL CRCM
Joined: Feb 2003
Posts: 766
Big Sky Country
Basically, if your assets were greater than $250 Million for two consecutive years in a row (as of 12/31 of each year), you are a large bank.

Here's some info:

http://www.ffiec.gov/cra/reporter.htm
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Me, Type A? Maybe - I'm not done analyzing it yet.

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#64412 - 02/28/03 12:57 AM Re: CRA- From small bank to large bank
SMQ, CRCM Offline

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SMQ, CRCM
Joined: Apr 2001
Posts: 4,825
Between the lines
Quote:

My bank also just finished the two year transition period and is now classified as a large bank, too.


Rebekah & jbest, welcome to the "I Hate HMDA-CRA Club"!! It's most appropriate that you guys are joining at this time of year---"I Hate HMDA-CRA Week"!! And, just like Secretaries Week & Day; we have an "I Hate HMDA-CRA Day" It is generally set for March 1, but sometimes is later, like this year, March 3!!!

I too joined the Large Bank ranks recently, submitting my first HMDA last year and my first CRA this year. Could not possibly make any sense of this without BOL; and many, many thanks to the BOLers who have saved my sanity with the frivolity along the way. It is amazing how knowledgeable these people are and how willing they are to share what they know. And, what a treat for me when I can give a little back. This site will be your MVR (Most Valuable Resource) and your salvation.
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#64413 - 02/28/03 02:13 AM Re: CRA- From small bank to large bank
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Quote:

This site will be your MVR (Most Valuable Resource) and your salvation.



Not to mention - addiction!
Don't ask - just click here
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#64414 - 02/28/03 02:31 AM Re: CRA- From small bank to large bank
SMQ, CRCM Offline

Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,825
Between the lines
Bonnie-------

Thanks,

Or this Help
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#64415 - 02/28/03 07:39 PM Re: CRA- From small bank to large bank
I Wear Many Hats Offline
Platinum Poster
I Wear Many Hats
Joined: Mar 2001
Posts: 591
the beautiful state of ME
My job description says "will act as the bank's CRA officer" - no further job description than that.....

opinions are mine and mine alone
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The paradox of planning is nothing happens....

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#64416 - 02/28/03 08:21 PM Re: CRA- From small bank to large bank
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Oh good gravy Sue...RUN fast and far!

I'm going to answer this post next week with some details on what I did when I started. I pretty much re'did the department as our past was rather umm well different and not "outstanding" like we are now

I made a huge amount of changes that impacted the bank as a whole, but in a very positive way (well the lenders might not think so but alot of others do) LOL
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#64417 - 02/28/03 08:51 PM Re: CRA- From small bank to large bank
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
I sent this via e-mail, but thought I would also post hit here for those lurkers who may also want to know:

The job description for CRA Officer will really depend upon how your bank wants to break down the job duties. An outline of all stuff CRA related will include several components from a technical side (the Data submission), a marketing/business development side (otherwise how will you make those Community Development loans and services), a performance review side, and an Investment side.

Technical component:
1. Gather loan data for the submission of the CRA Loan Register due March 1st of each year. This involves determining which loans are reportable, the correct dollar amount to report, and the proper address to use for the geocode. While this description sounds simple, it involves much more work than you can realize until you actually start trying to make these determinations.
2. Submit said loan register.
3. Create and maintain the CRA Public file for both the Main file and the ones to be kept in each branch. Be sure to check the
4. Make sure each branch and the Main Office has the correct CRA Notice posted in the lobby.
5. Maintain a listing and map of the Assessment Area for the Bank.

Marketing/Business Development
1. Make contacts with various community groups for Community Deveopment lending, service and investment opportunities.
2. Serve on the Board/Loan Committee/Finance Committe, etc. of groups that provide services to low- and moderate-income persons, or provide affordable housing, or other community development activities.
3. Be prepared to go to meetings, conferences, workshops, and one-on-one contacts with the various players involved in community development activities. Keep up with what regulatory agencies offer in terms of roundables and conferences in this area.
4. Locate businesses in Enterprise Zones, Redevelopment Areas, etc., for Community Development lending opportunities.
5. Prepare a budget of donations for various organizations that provide Community Development services (examples include Habitat for Humanity, a local chapter of a Neighborhood Housing organization, small business development or technical assistance providers, homeless shelters, child care centers in low/mod income areas, etc.)

Performance Review
1. Gather information on the community development lending, service and investment activity. Survey officers of the bank to locate any organizations they are involved with that can be considered for community development service credit. Review investments and donations that qualify for community investment credit. Review the loan performance from the Small Business lending data and HMDA datea (whichever or both as applicable to your bank).
2. Prepare an analysis of the Bank's performance under the 3 tests in the Large Bank exam.
3. Present this information to Management (and/or the Board as appropriate) so they understand what the bank might expect during an exam. Present recommendations for enhancement to any areas where the performance is not strong.

Investment
1. Review the appropriateness of major Community Development investments such as mortgage-backed securities comprised of loans to low- and moderate-income homeowners (making sure the securities are not backed by Predatory Loans!), Tax Credits, Community Development Corporations, etc. Many of these investments carry an entry level price tag of $1Million or more, so investments must be considered from a safety and soundness perspective, a market and interest-rate risk perspective, as well as the Community Development merit.
2. Prepare a budget for Community Development Investments that is appropriate for the size of your bank. Review Performance Evaluations for banks that are similar in size to your own to find out what dollar amount of Investment has earned a rating that you would be comfortable with.

I know the above is not a complete list, so folks, please add your items below!
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#64418 - 02/28/03 08:58 PM Re: CRA- From small bank to large bank
Anonymous
Unregistered

What an excellent list!

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