Is it a requirement to have a Board Approved CRA Policy??

No, but it's a good idea. Exams now a days are more about risk, and management of your program, than anything else (ok your numbers can't suck) Having a policy in place that details your procedures, responsabilities, etc., is a plus in the eyes of an examiner. It shows you take the issue seriously, and know what you're doing

I don't believe there is a reqirement but it is a prudent thing to do.

Thanks for the advice!

The revised CRA examination checklist for federal examiners explicitly requires an examiner to review written CRA policy and to confirm it has been properly authorized by the BOD. So while written CRA policy may not be explicitly mentioned in the regulations, it is apparent that examiners expect a written policy to be a part of a bank's CRA program. The new emphasis on "process" focuses more on procedures, controls, documentation and "self-assessment" as an integral part of any bank's CRA responsibilities. Given the high potential for misunderstanding and errors, prudence would suggest written procedures and policies for every CRA lender. I have seen too many situations where the "right hand doesn't know what the left hand is doing" resulting in inconsistent loan classifications and compromised data integrity. Every lender should have written policies and procedures IMO.

We have ours reviewed by the board annually. That seems to work for us. Basically with the new policy they get a sheet stating what changes have been made.

Sunshine, if you'd like a policy to work from, feel free to email me (please email verses pm because I'm not always able to get those). You'll find my email address in my profile (click my name).