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#64552 - 02/28/03 04:18 PM CRA "Policy"
Anonymous
Unregistered

I am a fairly new employee with the financial institution I am currently at. I am the compliance officer and I've just been told I will take on CRA too. I have experience as a compliance officer... but not that much in CRA. So... pardon my questions.

We are considered a small institution for CRA purposes. I am in the process of compiling information to prepare a CRA self assessment. I've also found out that the CRA "Plan" is due for review at the March BOD meeting.

From what I gather the "plan" in really the CRA policy. In order to get my ducks in a row I always like to verify everything with the actual regulation and it's requirements. Since I am the first full time compliance person this bank has ever had... policies and procedures were sometimes written by individuals that weren't always up to speed on regs.

The first paragraph of the plan reads..." The Bank's CRA plan is designed to fully address the revised guideline endorsed by the Federal Financial Supervisory Agencies (FFSA) in the Federal Reserve Bank's Supervisory Policy Statement of April 5, 1989 (csc No. 89-52).

I cannot locate this Policy Statement anywhere! I've searched all websites I can think of. I looked in the Fed's Service books. Is this the most recent version?

HELP!

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General Discussion
#64553 - 02/28/03 04:49 PM Re: CRA "Policy"
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
Why not scratch the old and start anew? Just refer to Reg. BB, implementing the Community Reinvestment Act.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#64554 - 02/28/03 04:59 PM Re: CRA "Policy"
A D Virr Offline
Gold Star
Joined: Oct 2000
Posts: 398
Derry, NH
I agree Andy, however if anon is an FDIC regulated bank, it is best to defer to FDIC rules and regs. FDIC differs slightly regarding CRA. Anon, the best advice that I would contribute to your plight is to see if you can obtain a copy of the ABA publication "The New CRA - Executive Summary." It might be out of print but I would call ABA to see if you could get a copy. Another souce of CRA info is your regulators examination guidelines which can be found on line and also through BOL. Good luck.
_________________________
Allan D. Virr, CRCM,CRP
Compliance Audit Solutions, LLC

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#64555 - 02/28/03 05:03 PM Re: CRA "Policy"
SJB Offline
Diamond Poster
SJB
Joined: Jun 2002
Posts: 1,210
California
Ditto the above. There have been big changes since that 1989 publication so don't even bother with it.
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My opinions are not legal advice and are worth what you paid for them.

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#64556 - 02/28/03 06:00 PM Re: CRA "Policy"
Anonymous
Unregistered

Okay... so then I am really lost. Do I even need a "Plan", "Statement", or "Policy"? Since I am a small bank it appears as long as I've described my assessment area, maintain an accurate, up-to-date public file, and post the public notice I good to go!?? Of course I am still going to preform a self assessment...













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#64557 - 02/28/03 06:14 PM Re: CRA "Policy"
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
It isn't a regulatory requirement, but it can be a good thing to do as it can reinforce your commitment. You shouldn't be criticized for not having it so long as your Public File is in place and procedures are working.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#64558 - 02/28/03 06:22 PM Re: CRA "Policy"
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,983
FINALLY ABOVE the gnat line
This is our first year as a large bank under CRA, but our small bank procedures were as follows:

1) lobby notice
2) public file
3) Board approved policy

Our Board approved the policy every year. It contained the following items:

1) overview of regulations and small bank performance standards
2) STatement that we will be in compliance with everything!
3) Assignment of responsibility - Starting with the BOD, the examiners like to see the board involved with CRA. Then detail what management's responsibility will be and finally, the CRA officer's responsibility.
4) Training - how frequently and who will be trained
5) Banking Office Closure Procedures - straight out of the FDIC manual
6) Procedures - a section that provides specific procedures for determining how you will determine your assessment area, how you will track the loans made in the assessment area, what goes in your public file, when these reports or items will be accomplished (mo, qrtly,semi,etc), & a copy of the lobby notice.
7) We also included monitoring procedures for how freqently the IA or compliance officer would review compliance with this policy or regulation.

This seemed to work for us. Good Luck!
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- Frederick Douglass




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#64559 - 02/28/03 06:26 PM Re: CRA "Policy"
Lucy Griffin Offline

Diamond Poster
Lucy Griffin
Joined: Nov 2000
Posts: 1,544
You should have a policy -- and one that reflects the current regulation, not the old regulation! Sounds as though they need you!

As a small bank, define your assessment area, place public files where required (and make sure they have all the required contents), post the notice, and train folks to know what CRA is about, what Low and Moderate income are for your market, and so forth. You don't need a plan. In fact, now the word "plan" generally refers to a strategic plan under the new regulation.

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#64560 - 02/28/03 07:12 PM Re: CRA "Policy"
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Anon, I wouldn't mind sharing mine with you via email, but you'd have to weed out the Large Bank differences. I prepared mine using a book called:

Community BankTools
Writing an Effective CRA Policy

It's put out by the ABA and was fairly simple to follow. I did have to add information on compliance with the Sunshine Act, but that was rather easy. I bought a couple of other books to produce one, but this one was the KISS version and was by far the best I saw.
_________________________
Dawn Coursey VP/CRA Queen

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

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#64561 - 02/28/03 07:27 PM Re: CRA "Policy"
RebekahL CRCM Offline
Platinum Poster
RebekahL CRCM
Joined: Feb 2003
Posts: 874
Big Sky Country
Dawnie,

I'm not anon, but I'd like to get a copy too, if you don't mind. Since my bank is new to large bank standards (this year), taking a peek at your info would do me some good, I'm sure!

rebekahl@ourbank.com

Many thanks!
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Me, Type A? Maybe - I'm not done analyzing it yet.

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#64562 - 04/18/03 07:39 PM Re: CRA "Policy"
Anonymous
Unregistered

Dawnie, I saw this just recently and was wondering if you share the same with me as I too am looking for something to go by to create a plan of sorts. If you are willing, my email address is jenningc@snbtx.com. Thanks for help!!

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#64563 - 04/18/03 07:46 PM Re: CRA "Policy"
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
It's in your email
_________________________
Dawn Coursey VP/CRA Queen

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

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