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#64552 - 02/28/03 04:18 PM
CRA "Policy"
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Anonymous
Unregistered
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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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#64553 - 02/28/03 04:49 PM
Re: CRA "Policy"
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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Why not scratch the old and start anew? Just refer to Reg. BB, implementing the Community Reinvestment Act.
_________________________
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"
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Gold Star
Joined: Oct 2000
Posts: 398
Derry, NH
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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"
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Diamond Poster
Joined: Jun 2002
Posts: 1,210
California
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Ditto the above. There have been big changes since that 1989 publication so don't even bother with it.
_________________________
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"
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Anonymous
Unregistered
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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"
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10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
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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"
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Power Poster
Joined: Nov 2001
Posts: 7,988
FINALLY ABOVE the gnat line
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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!
_________________________
"Once you learn to read, you will be forever free." - Frederick Douglass
My Opinion Only.
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#64560 - 02/28/03 07:12 PM
Re: CRA "Policy"
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Power Poster
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
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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"
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Platinum Poster
Joined: Feb 2003
Posts: 879
Big Sky Country
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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.comMany thanks!
_________________________
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"
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Anonymous
Unregistered
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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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