We are having our CRA/Compliance exit this afternoon. We're FDIC and 2.1B in assets. The remote exam was almost surreal, as we only talked with the exam team maybe twice a week.
They went very high level on loan review, as their samples were 8 TRID loans, 2 HPML loans, 10 denials, 3 credit cards, and 3 HELOCs. Oddly, they seemed to focus on how credit card payments we applied, specifically, compliance with 1026.53. We hadn't seen that before.
They reviewed any advertised benefits on any accounts to make sure that the customer received the benefit. That's been a huge focus the last two exams for us. Anything that looks like customer harm is a priority.
For our CRA story, we included all our PPP loans and the jobs retained, the waived extension/modification fees, payment deferral programs, etc.
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All opinions are my own, not my employer's